Privacy Policy

Introduction & Background

The purpose of this policy is to outline how the FlexTrade Group has established measures to protect your privacy rights. This policy describes how we collect, use, disclose, share and protect Personal Information that we collect from you in connection with your use of our website (www.flextrade.com) and dependent pages (the “Site”), or your purchase or use of our B2B products and services. You may receive supplemental information concerning our collection and processing Personal Information when you purchase our B2B products or services or set up a user account on our B2B systems.

This Privacy Policy applies to all FlexTrade Group Companies including FlexTrade Systems Inc., FlexTrade UK Ltd., and subsidiaries owned and operated by FlexTrade (“FlexTrade”, “We”, “Us”, “Company.”) The use of Personal Information collected through our products and services shall be limited to the purpose of providing the products and services for which a client has engaged FlexTrade to perform. We collect and process your Personal Data fairly and lawfully in order to carry out our lawful business activities.

Individuals’ Rights

We recognize that, depending on where you live, you may have rights as a ‘data subject’, or “consumer” and that we have an obligation to uphold these.

Residents of the European Union and United Kingdom may access the Notice of Collection of Personal Information and Privacy Policy with information and rights required by the General Data Protection Regulation (“GDPR”)/UK GDPR through the link here or by scrolling down. California residents may access the Notice of Collection of Personal Information and Privacy Policy with information and rights required by the California Consumer Privacy Act (CCPA) through the link here. Residents from other states having data privacy laws may scroll down or click here for information and rights required under those states’ respective laws to the extent applicable to the individual consumer.

Personal Information We Collect (Through FlexTrade’s Sites)

For purposes of this Privacy Policy, we refer to Personal Information according to the following definition: “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual or household. Personal information does not include publicly available information or information that is de-identified or aggregate consumer information. Personal information may include in this context identifying information about an individual such as a name, title, company name, address, email address, phone number and other B2B related contact information. Information is examined and edited, as necessary, for accuracy. Additional or missing public information – such as company location, industry, etc. – may be appended with the aid of third-party sources for sales and marketing purposes.

We may collect and otherwise process Personal Information from and about you in various ways:

when you voluntarily provide us with information;
when you communicate with us concerning our B2B products or services,
when you place an order with us for our B2B products or services,
through automated means when you use our Site including through use of “cookies,” web beacons, pixels and other similar technologies that track your online activity, including your use of our Site. Depending on where you live we may ask for your consent before lodging cookies or tracking technologies; and
through information provided by third party vendors who analyze your usage of our Site.

We collect Personal Information that you voluntarily provide to us when you: use our Site, communicate with us, make a purchase, use our products or services, provide us information, engage or connect with us through one of our social media pages, update or when you otherwise correspond with us.

In addition, we also automatically collect Personal Information about you in connection with your usage of our Site, including from third party marketers and platforms that monitor usage of our Site.

By accessing our Site or social media pages, submitting Personal Information to us, or purchasing our products or services, you consent to the processing, collection, use, sharing and disclosure of such information as set forth in this Privacy Policy, as it may be updated from time to time. FlexTrade is the sole owner of the information collected on and through the Sites.

FlexTrade collects Personal Information from our users at several different points on our Site.

Registration or other online forms

When using our Site, applying for job openings and requesting more information, you often must first complete a registration, request a demo form, sign up for products, events or news or insights forms, or other request to contact form. During registration or otherwise when completing such forms, you are required to give contact information (such as first and last name, email address, telephone number and company name). We use this information to contact you about the services offered by FlexTrade in which you have expressed interest.

Requests for information about our B2B products and services

FlexTrade collects Personal Information about individuals when such individuals specifically provide such information to us on a voluntary basis. This includes, for example, when we are contacted asking for marketing or other descriptive materials about our B2B products and services. We may collect the email addresses of those who communicate with us via email and other information volunteered by the user.

Information Collected Automatically

We also collect information automatically when you visit our Site through the use of “cookies,” web beacons, pixels, scripts and similar technologies that track your online activity, including your usage of our Site. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, referring/existing pages, and the pages you visit. Cookies are small text files sent by your computer or device each time you visit our Site, which are unique to your browser or device. We use first party cookies and services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and to provide you with advertising. Third parties may use third party cookies to collect information when you visit their websites for their own business purposes. Cookies help us learn which areas of our Site are useful and which areas need improvement. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our products to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. By using our Site, you consent to the use of all cookies and tracking technologies. You can choose whether to accept cookies by changing the settings on your browser or visiting our Privacy Center. Please consult your Internet browser’s documentation for information on how to do this. However, if you choose not to accept functional cookies, the Site may not function properly, and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us.

Information We Collect (Purpose of Processing)

FlexTrade intends to use your Personal Data, collected through the Website, for the following business and other legitimate purposes:

To respond to your requests for further information, to allow you to receive updates about FlexTrade’s products and services (FlexTrade’s e-Newsletter) and to provide any other Services which you may request;
To examine applicants’ resumes/CVs and to get in contact with applicants who have submitted their application via the Website;
For marketing, promotional and publicity purposes, including to carry out direct marketing and targeted advertising, market research and surveys;
To manage and improve the functionality, security and effectiveness of our Site;
To manage your business account; and
For compliance with laws which impose upon FlexTrade the collection and/or further processing of certain kinds of Personal Data, as well as, where necessary, for establishment, exercise or defence of legal claims.

Information We Collect (Through Cloud and Messaging Services)

The use of information collected through our products or services shall be limited to the purpose of providing the products or services for which the Client has engaged FlexTrade. We generally function as a “processor” of Client data and will provide further information at time of contracting.

FlexTrade may, in certain circumstances, have Personal Information of its clients transmitted into its data centers and has no direct relationship with the Personal Data of individuals of its clients, and in most circumstances, no access or viewing of any individuals’ data residing on its clients’ servers that is being processed in its data centers. If you are a client of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our clients.

Any Personal Information that is transmitted in the provision of services will only be processed or retained as long as needed to provide services to our clients. Further, we will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and to enforce and abide by our contractual agreements.

Disclosures of Personal Information to our Vendors

The information FlexTrade collects is used to improve the content of its websites, customize the content and/or layout of the websites’ pages for each individual user, to notify users about updates to the websites and to contact users for marketing purposes, including targeted advertising. FlexTrade provides your Personal Information to service providers who work on behalf of or with FlexTrade and under agreements to provide services such as help desk management and archiving services. Such service providers may be provided with access to your Personal Information to perform the functions for which they have been retained. FlexTrade requires its service providers, who provide services on our behalf to maintain the privacy and security of your Personal Information.

Disclosures of Personal Information in the event of Merger/Acquisition

FlexTrade may disclose your Personal Information in the event that FlexTrade, or any affiliated entity, or substantially all of its assets related to a particular geographical region, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, as your information may be one of the transferred assets.

Transfers of Data (International Transfer of Data)

In order to provide our services or products or fulfill your requests, we may need to transfer Personal Information to locations outside the local jurisdiction in which you are viewing the Site and process Personal Information outside that jurisdiction for the purposes set out in this Privacy Notice. This may include transfer of your Personal Information to the United States where FlexTrade’s headquarters are located. By providing us with your Personal Information, you consent to the transfer of your Personal Information outside the local jurisdiction in which you are viewing the Site, including for purposes of fulfilling your request.

Links to Third-Party Websites

FlexTrade websites contain links to other sites owned and maintained by companies other than FlexTrade. Those companies’ privacy practices may differ from FlexTrade’s. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. FlexTrade is not responsible for the privacy practices or the content of such websites. Users should check the applicable privacy policy of such linked websites.

Our website includes Social Media Features, such as button links to Twitter and Linkedin.com. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are hosted by a third party. Your interactions with these features are governed by the privacy policy of the company providing it.

Retention of Data

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may deidentify or anonymise your Personal Information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Security

To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain reasonable physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. Therefore, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control. We restrict access to your Personal Data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your Personal Information.

Use of Tracking Technologies/Disclosure of Personal Information to Third Parties

We, and our partners, affiliates, or analytics and online service providers, and third party advertisers use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We and our third-party partners use Local Storage (HTML5) to provide certain features on our website to display advertising based on your web browsing activity, and/or to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.

The use of tracking technologies on our Site may result in the disclosure of your Personal Information to advertisers, social media companies and other third providers. FlexTrade is not responsible for any actions or policies of such third parties.

This Notice of Collection of Personal Data and Privacy Policy (“GDPR Privacy Notice”) applies to the collection of Personal Data from residents of the European Union on or after May 25, 2018. This GDPR Policy Notice supplements our Privacy Policy above to provide European Union residents with information and rights required by the General Data Protection Regulation (GDPR). This GDPR Privacy Notice aims to outline how we maintain these rights. In particular, it outlines:

How we collect and process your information
Why we do this
How you can exercise your rights;

For purposes of this GDPR Privacy Notice, we refer to Personal Data according to the following definition given in the GDPR: “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

When we refer to “processing” in this GDPR Privacy Notice, we mean any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

By submitting Personal Data to us, or purchasing our products or using our online services, you consent to the collection, use, sharing and disclosure of such information as set forth in this GDPR Privacy Notice, as it may be updated from time to time.

FlexTrade is committed to processing Personal Data only where there is a lawful basis:

where you have given consent to the processing of your Personal Data for one or more specific purposes. Where the sole basis for our use of the Personal Data is your consent, you have the right to withdraw your consent at any time;
where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
where processing is necessary for compliance with a legal obligation to which FlexTrade is subject;
where processing is necessary for the purposes of the legitimate interests pursued by FlexTrade or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data. FlexTrade’s legitimate interests include to effectively manage our business and customers, market, sell and deliver our products, including providing advertising content and opportunities, manage accounts, improve our services and products, maintain the security of our Site, and comply with our legal obligations
processing of special category Personal Data shall only occur where you have given explicit consent to the processing of the Personal Data for one or more specified purposes or where permitted by applicable law. (Note, that we do not ever request or require that you provide us with special category data).

Your privacy rights are as follows:

Right to be informed: This encompasses the obligation for us to be transparent in how we collect and use your Personal Data.
Right of access: You have the right to access your Personal Data and request certain supplementary information concerning our use of your Personal Data, such as an explanation of the purpose of the processing, categories of Personal Data processed and disclosure of third parties with whom FlexTrade shares the data.
Right to rectification: If the information we hold on you is inaccurate or incomplete, you can request we correct this.
Right to erasure: You can request we delete or remove Personal Data under certain circumstances. For example, you may request erasure if the data is no longer needed in connection with the reasons it was collected or processed or if (the sole basis for processing is consent) you withdraw your consent to further processing. FlexTrade may deny your request where it is required or permitted by law to retain your Personal Data or when we need to retain your information in connection with the exercise or defense of legal claims.
Right to restrict processing: You have the right to request we cease processing your data, if you consider it inaccurate or incomplete.
Right to data portability: by requesting a copy be provided in a structured, commonly used and machine-readable format and/or requesting that FlexTrade transmit your Personal Data to a third party where technically feasible.
Right to object: You have the right to object to our use of your Personal Data where you contest that the processing is necessary for the purposes of FlexTrade’s legitimate interests. FlexTrade may deny your request because it has compelling legitimate business interests or in connection with the exercise or defense of legal claims. You also have the right to advise us at any time that you no longer wish to receive direct marketing materials from FlexTrade and we will no longer use your Personal Data for marketing purposes.
Rights relating to automated decision-making including profiling: The GDPR has provisions on automated employee decision-making (making a decision solely by automated means without any human involvement) and Profiling (automated processing of personal data to evaluate certain things about an employee). Profiling can be a part of an automated decision-making process. FlexTrade ensures it has a lawful basis to carry out profiling and/or automated decision-making and documents this. FlexTrade only collects the minimum amount of data needed and has a clear retention policy for the profiles we create.

This privacy notice should outline how we are transparent in our processing. Please get in touch with us through the ‘contact details’ section to find out more or to exercise your privacy rights.

You have the right to bring a complaint before the applicable governmental privacy regulator.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the FlexTrade (the data controller) to GDPRManager@flextrade.com. If a FlexTrade prospective client or candidate requests FlexTrade to remove the data, we will generally respond to their request within 30 days.

Notification of Changes

Please check our GDPR Privacy Notice periodically as FlexTrade reserves the right to change this Privacy Policy at any time. Changes to FlexTrade’s GDPR Privacy Notice will be posted to this website.

Contact Details

We recognize that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future.

If you have given consent for processing, you are free to withdraw that consent. To let us know this is the case please email us at GDPRManager@FlexTrade.com

If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access):

FlexTrade, as data controller, can be contacted as follows by post at FlexTrade Systems, 111 Great Neck Road, Suite 314, Great Neck, NY 11021 or via phone at +44 (0)-203 757 9316.
The FlexTrade data compliance officer can be contacted as follows at GDPRManager@FlexTrade.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about your data. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the UK, you have the right to lodge a complaint with the UK Supervisory Authority for Data Protection Law, The Information Commissioner’s Office (ICO). The ICO can be contacted through their website at https://ico.org.uk/concerns/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.

FlexTrade State Data Privacy Notice

This State Privacy Notice applies to the collection of Personal Data from residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia on or after the effective date of privacy laws in those states to the extent applicable. This State Privacy Notice supplements the information above to provide those residents with rights and information required in the aforementioned states under the applicable data privacy law.

As explained in our Privacy Policy, we do not sell your Personal Information. FlexTrade may provide your Personal Information to third parties, including advertisers, to provide you with marketing information that may be of interest to you. The provision of your Personal Information to these third parties may constitute “targeted advertising” under these data privacy laws. If you do not want your Personal Information disclosed for “targeted advertising,” including through third party cookies, please see our Privacy Preferences Center by clicking the popup on the bottom left of your browser. To opt-out of “Targeted Advertising”, be sure that both the “Analytics” and “Targeted advertising (including real-time sharing)” checkboxes are not checked, and then click Confirm.

In addition to the disclosures in our notice above, you may exercise your rights under those laws, including, as applicable, rights to access, correct, delete, portability, to opt out of certain processing, including profiling or targeted ads by telephoning us at +44 20 3757 9316 or sending us an email to GDPRManager@FlexTrade.com. You have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial. Your rights will be determined by the particular state you live in.

Last Updated: September 2025