Effective Date May 25, 2018
Your privacy is extremely important to Vela Trading Systems LLC (formerly OptionsCity Software) and so is being transparent about how we collect, use and share information about you. This privacy statement is intended to help you understand:
- what information Vela collects and why we collect it;
- the ways in which Vela uses that information;
- the third parties we may share it with and why;
- what information may be transferred internationally;
- how information is stored and protected;
- the rights you have to access and control your information;
- how long we keep your information for.
Information we collect
When you register for our website, complete a contact form, subscribe to any services or use our products and services, we may collect data or ask you to provide certain data for the purposes of helping us manage our relationship with you.
The types of personal data we may collect are:
- Your name, company name, email address, phone number and country when you register for our website, complete a contact form, download any materials, request a demo or complete a ‘find out more’ form on our website enquiring about our products and services;
- Online account details including username, password and other credentials used to access Vela’s products and services when you create an account with Vela;
- Your name, address, business contact, billing contact, email address, phone number, billing contact, billing address, billing email and phone number when you enter into a Contract with us and purchase our products and Services;
- We may ask you for information to enable us to provide a Service to you and we collect this information by telephone, written/digital correspondence or via the website;
- Any other information that you voluntarily submit to / send to the website.
- Technical Data such as [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
- Profile Data such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- Your name, job title, company name and email address when you take part in any competitions, surveys or promotional events hosted by Vela.
- Usage Data such as information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
How we use information we collect
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to such activity at any time by email or using the UNSUBSCRIBE option available on the communication.
On the basis of fulfilling our contract with you, your personal information may be processed for purposes including:
- Manage and administer our customer relationship with you;
- To provide products and services you have contracted with us for;
- To provide information you have requested and to contact you in relation to any queries you may submit;
- To administer, enable you to access to and use of our website;
- Supply you with any services that you subscribe to e.g. newsletter / RSS;
- To manage your accounts, orders, invoices and payments;
- To manage and provide technical support for products and services and an after-sales service.
On the basis of legal obligations, we are obligated to, for instance, keep records for tax purposes or regulatory purposes for particular products and services.
Sharing your information with others
Your personal data may be disclosed to third party service providers, acting on our behalf, in connection with:
- providers of cloud based CRM software to support customer account maintenance and billing;
- providers of cloud based marketing software to provide management of prospective customer information;
- providers who provide data analytics functionality;
- providers of cloud based accounting software to support the management of finance and accounting.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Vela may also disclose your data to a third party who acquires all or a substantial part of our business by way or merger, consolidation or purchase of a substantial proportion of our assets.
In addition to the disclosures reasonably necessary for the purposes listed above, Vela may disclose your personal information to the extent that is required by law and in order to establish, exercise or defend its legal rights.
As a global company with a number of different international entities under the Vela Trading Systems LLC parent entity, we rely on shared services, some of which are located outside of Europe and so your information may be transferred internationally.
We have implemented strict processes to ensure that your data is protected when transferring data in this way and we will only transfer your personal data in this way if one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Securing your data
Vela shall act as the data controller of any personal information that we receive from you and we are committed to ensuring the security of this data. Vela will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. Vela has appropriate policies and technical and organizational measures in place to safeguard and protect your personal data against unlawful or unauthorized access, accidental loss or destruction, damage, unlawful or unauthorized use and disclosure.
All employees follow a security training program to ensure they have adequate training with regards to handling personal data.
If despite our security procedures personal information is inadvertently disclosed, we shall use all reasonable endeavors to limit and remedy the disclosure but to the extent permitted by law we accept no liability for unintentional disclosure.
You have rights relating to the way in which we use your data and you may exercise these rights by contacting us via the details provided in the ‘Contact Us’ section. Subject to the applicable data protection laws, you have the right to:
- request a copy of the personal data Vela holds about you;
- have any inaccurate information about you corrected, you can also make updates to your personal data via the website;
- request erasure of the data Vela holds on you;
- withdraw any consent you have given to us in relation to the processing of your personal data;
- restrict the processing we make in relation to your personal data;
- restrict the use of your details for marketing activities and other promotional activities;
- object to the processing of your personal data;
- request the transfer of your personal data to another party;
- lodge a complaint with the Information Commissioners Office.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How long we keep information for
We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from using the contact details provided below.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
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Links to other websites
www.optionscity.com and www.tradevela.com contains links to partner companies and third party websites. If you follow a link to any of those third-party websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those practices. Please check those policies before you submit any personal data to those websites.
Privacy Team, Vela Trading Systems LLC, Adelaide Exchange, 24-26 Adelaide Street, Belfast, BT2 8GD or email at firstname.lastname@example.org