1. Important information and who we are


Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of our website and/or our app or otherwise when you communicate or interact with us in the course of business.

This version of our privacy notice was last updated on 21 February 2019.


Controller

AI Exchange Limited is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.

If you have any questions about this privacy notice or about your rights, please contact us.


Contact details

We are: AI Exchange Limited of 20 St. Dunstan's Hill, London, EC3R 8HL.

If you need to get hold of us for any reason in connection with your personal data, please email us at [email protected].

We are registered with the Information Commissioner’s Office (ICO) and we have ICO registration number ZA475242. You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.


2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • • Contact Data includes name, role at business, email address, phone number – for all individuals we work with.
  • • Correspondence Data includes email correspondence, notes of conversations, recorded conversations – for all individuals who choose to interact with us.
  • • Trader ID Data includes date of birth, ID documents such as copies of: passport, utility bills, driving licence or other documents that verify the identity of those who choose to trade with us.
  • • Trader Financial Data includes bank account and payment card details of those who choose to trade with us.
  • • Trader Transaction Data includes the trading records of those who choose to trade with us.

  • • Trader Profile Data includes a username, password or other information unique to those who choose to trade with us.
  • • Marketing Data includes any preferences in your receiving marketing from us.
  • • Usage Data includes information about how visitors use our website and/or app.
  • • Technical Data in connection with use of our website and/or app, includes 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 and/or app.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • • Direct interactions. We collect the majority of your data when you choose to give this to us on our website and/or through our app, by email, by mail, over the phone, in person at meetings or otherwise. Because of the nature of our business, by law, some of our telephone conversations are required to be recorded.
  • • Third parties. If you choose to trade with us, we may be required to collect or verify certain information about you from third parties
  • • Automated technologies or interactions (COOKIES). As you interact with our website and/or our app, we may automatically collect and be provided with Usage Data and Technical Data from certain “performance” or “session” cookies like Google Analytics about your browsing actions and patterns. For further information, see section 5 below.

4. How we use your personal data

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:

  • in anticipation of or accordance with an agreement that we have with you (for example where you wish us to enable a trade on your behalf); or
  • where we need to comply with a legal or regulatory obligation (for example where we are required to verify a trader’s identity or record a telephone instruction in order to comply with financial regulations);
  • where it is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you and to improve the service that we offer);
  • where you have provided your consent (for example to receive our marketing emails)
    • Please contact us if you need further detail about the specific legal ground we are relying on to process your personal data.


5. Cookies

We use performance and session cookies because it helps us to understand how visitors arrive at our website, browse or use our website and highlight areas where we can improve areas such as navigation and marketing campaigns. Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you wish to disable the Google Analytics cookies that we use, you can do so by following this link: https://tools.google.com/dlpage/gaoptout.


6. Disclosures of your personal data

We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

Companies that act as data controllers of your personal data:

  • Seed CX Limited, based in the US. Seed CX is our current trading platform, and facilitates all trades - they may require further specific information from you in order to facilitate a trade. Seed CX acts as a data controller of your personal data and their privacy policy is accessible here: https://seedcx.zendesk.com/hc/en-us/articles/360009900494-Privacy-Policy-
  • Credit Safe, based in the UK. We may transfer your personal information to Credit Safe where we need to carry out anti-money laundering checks and otherwise to verify the information that you provide to us. Credit Safe acts as a data controller of your personal data and their privacy policy is accessible here: https://www.creditsafe.com/gb/en/legal/privacy-policy.html
  • Financial regulatory bodies or government organisations or fraud prevention agencies where we are required to submit certain information to them.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Companies that are our service providers and that act as data processors of your personal data:

  • Our service providers who provide us with IT management and system administration and management and other support services.
  • Website/app analytics providers.

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. We require all third party service providers to respect the security of your personal data and to treat it in accordance with the law.


7. International transfers

A number of the companies that provide support services to AiX and need to process personal data on our behalf have servers based in the US or elsewhere outside the UK or the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the UK and/or outside the EEA.

Our service providers are required to ensure a similar degree of protection is afforded to your personal data by ensuring that either:

  • we have a specific contract with that processor in a form approved by the European Commission which ensures that service provider gives your personal data the same protection it has in Europe; or
  • if the provider is based in the US, it is a member of the US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or
  • the European Commission has ruled that the country to which your information is transferred has an “adequate level of protection” in place.

And if none of those applies, we may also transfer your personal data to a service provider based outside the UK or the EEA if we consider that the transfer is necessary for the performance of a contract between you and us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.


8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


9. Data retention
How long will you use my personal data for

We will only retain your personal data 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. If you trade with us, by law we have to keep the majority of your data for seven years after we stop working together. Certain data (such as Technical and Usage Data and Marketing Data is kept for significantly shorter periods. In some circumstances you can ask us to delete your data: (see below for further information).

In some circumstances we may anonymise 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.


10. Your legal rights

You have the right in certain circumstances to:

  • Request access to your personal data (a "data subject access request").
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data (if it is no longer needed for the original purpose for which it was collected – for example your Marketing Data or your Usage and Technical Data)
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.

For more information on these rights and when they apply is available here:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

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.