Introduction & Background
The purpose of this policy is to outline how the FlexTrade Group has established measures to protect your privacy and information rights.
We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these. This 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;
- Who to contact in the event you’re unhappy with our performance.
Your information 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 supplementary information.
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 where there is no compelling reason us to continue processing
Right to restrict processing
You have the right to request we cease processing your data, if:
- You consider it inaccurate or incomplete;
- here you object to processing and we are considering whether we still have a legitimate interest to process it.
- Where we don’t need the data for the original reason we collected it, but may need it to support a legal claim
Right to data portability
Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.
Right to object
You have the right to object to our processing under certain circumstances. For example, you can object to:
- direct marketing (including profiling); and
- processing for purposes of scientific/historical research and statistics
Rights relating to automated decision making including profiling
Where we apply automated decision making we must:
- give you information about the processing;
- introduce simple ways for you to request human intervention or challenge a decision;
- carry out regular checks to make sure that our systems are working as intended
Information related to automated decision making is contained later in this notice.
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 information rights.
Information We Collect (Through FlexTrade’s Websites)
When using the referenced websites, applying for job openings and requesting more information, you often must first complete the registration form. During registration you are required to give contact information (such as first and last name, email address and company name). We use this information to contact you about the services offered by FlexTrade in which you have expressed interest.
FlexTrade is the sole owner of the information collected on the websites. FlexTrade collects personal information from our users at several different points on our websites.
FlexTrade does not collect personal information about individuals except when such individuals specifically provide such information to us on a voluntary basis. Personal information in this context is identifying information about an individual such as a name, title, company name, address, email address and phone number. 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.
FlexTrade may also collect IP addresses and/or Domain Names (where applicable) of visitors to its websites, the email addresses of those who communicate with us via email and information volunteered by the user, such as survey information and/or website registrations. FlexTrade may use IP addresses and or Domain Names to help diagnose problems and to administer the websites. 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 website(s), to respond to requests for information, send newsletters, assess applications such as partner and job applications and to contact users for marketing purposes. The information gathered may be shared with trusted vendors that partner with FlexTrade to deliver technology and support services in which you express interest.
Information We Collect (Purpose of Processing)
FlexTrade intends to use your Personal Data, collected through the Website, for the following 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 (“Service Provision”);
- To examine applicant’s resumes/CVs and to get in contact with applicants who have submitted their application via the Website (“Recruitment”);
- For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via (“Marketing”); 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 (“Compliance”).
Information We Collect (Through Cloud and Messaging Services)
The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged FlexTrade.
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. 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 respond to their request within 30 days.
Transfers of Data (Data Sharing)
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. FlexTrade provides your information to trusted vendors who work on behalf of or with FlexTrade and under confidentiality agreements to provide services such as help desk management and archiving services. However, these companies do not have any independent right to share this information.
FlexTrade may share 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.
Aggregate data and information that otherwise is not personally identifiable to you may be disclosed to others.
Transfers of Data (International Transfer of Data)
FlexTrade has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. The IAPP relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, FlexTrade collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of the FlexTrade in a manner that does not outweigh your rights and freedoms. FlexTrade endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with FlexTrade and the practices described in this Privacy Notice. FlexTrade also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.
Transfers of Data (Links to Third-Party Websites)
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 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. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.
To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. 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 information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
If you have any questions about the security at our website, you can send an email to GDPRManager@FlexTrade.com.
Use of Tracking Technologies
We, and our partners, affiliates, or analytics and online service providers, use 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.
Users should also be aware that non-personal information and data may be automatically collected through the standard operation of the websites web server or through the use of ‘cookies.’ “Cookies” are used within the websites to track user traffic patterns. We do this in order to determine the usefulness of the information on our websites to our users and to see how effective our navigational structure is in helping users reach that information.
FlexTrade does not correlate this information with data about individual users, with the exception of users of forms on our site. FlexTrade may provide aggregated cookie data to third parties for analysis purposes. FlexTrade is not responsible for any actions or policies of such third parties.
If you prefer not to receive cookies on FlexTrade’s websites, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. You do not need to have cookies turned on to use any area of FlexTrade’s websites.
We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
Notification of Changes
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to FlexTrade or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
We recognise 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 +1516-627-8993, ext.8
- The FlexTrade data compliance officer can be contacted as follows at GDPRManager@FlexTrade.com.
If you are unhappy that we have responded to your query adequately, of if you have a further complaint, you have the right to contact the relevant data protection supervisory authority in whichever jurisdiction you are providing the information as a data subject.