This notice (privacy notice) applies to personal information we collect from you when you use this site. If you are a B2C2 customer, or otherwise have a relationship with us, we may also have provided you with a separate privacy notice setting out how we use your personal information, which will also apply.
B2C2 Ltd and its subsidiaries (collectively referred to as “B2C2”, “we”, “us”) take data protections and privacy responsibilities seriously. This privacy notice explains how we collect, use and share personal information in the course of our business activities, including:
• What personal information we collect and when and why we use it;
• How we share personal information within B2C2, with third parties and regulators;
• Using cookies and other technologies;
• Carrying out direct marketing;
• Transferring personal information globally;
• How we protect and store personal information;
• Legal rights available to help manage your privacy; and
• How you can contact us.
We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email (“Notice of Change”).
B2C2 collects information about you if you:
• Register with or use our Website or online services;
• Are a private client;
• Represent one of our institutional clients;
• Work with us as a service provider; or
• Visit a B2C2 office or register to attend a B2C2 event.
Personal information we collect will fall within one of the below:
• Your name and how to contact you – basic information about you, including your signature;
• Identification data including unique descriptors – Government issued identifiers, other unique identifiers such as date of birth, and personal descriptors that might identify you.
• Financial and transactional – financial information about you, transactional information and credit information, account authentication details.
• Contractual details – information collected as part of the products and services we provide you.
• Socio-demographic – includes details about your work or profession, nationality, education.
• Technical information – details about your devices and technology that you use to access our services, including IP address.
• Behavioural – information about how you use our products and services.
• Location – data we receive about where you are.
• Communications – information we capture through your communications with us, e.g. telephone conversations, emails and instant messaging.
• Publicly available information – details that are in public records and information about you that is openly available on the internet.
• Sensitive categories of data – the law and other regulations treat some types of personal information, including personal information relating to health and criminal convictions and offenses as special and affords them additional protections. We will only collect and use these types of data if the law allows us to do so.
Personal information we collect will be used for one or more of the following services:
• To manage your relationship with B2C2
— To manage our relationship with you or your business, for example how to best contact you
— To develop new ways to meet our clients’ needs and to grow our business, for example by seeking client feedback or sharing market research
— To develop and carry out marketing activities in order to keep our clients informed about our products and services
— To develop and manage our brand
• To administer the products and services we deliver
— To make and manage client payments
— To manage fees, charges and interest due on client accounts
— To collect and recover money that is owed to us
— To exercise our rights set out in agreements or contracts
• Crime prevention and detection
— To detect, investigate, report, and seek to prevent fraud, financial crime and anti-money laundering, for example through know-your-customer checks, AML screening and other identity checks
— To comply with other laws and regulations that apply to us
• To protect our brand, our business and our clients’ interests
— To manage risk for us and our clients
— To respond to complaints and seek to resolve them
— To comply with all applicable laws, law enforcement and regulatory requirements
— To protect our IT systems, network and infrastructure
— To run our business in an efficient manner, for example managing our financial position, planning, corporate governance or audit
The lawful basis on which we will collect and use this data will include:
• Legitimate interests – our use of your personal information is in our legitimate interest as a commercial organisation to provide services to our clients, provided our use is proportionate and respects your privacy rights, where we rely on our legitimate interest, we will tell you what that interest is. Our legitimate interests include:
— Working out which of our products or services might interest you and telling you about them
— Seeking your consent when we need to contact you
— Keeping our records up to date and honouring your communication preferences
— Ensuring we are able to effectively and efficiently meet our contractual obligations
— Complying with regulatory requirements
• Consent (where required by law) – you have provided your consent to us using the personal information, for example if you have agreed to receive marketing communications.
• Contractual obligation – our use of personal information is necessary to fulfil a contract we have with you or to take steps to enter into a contract with you, for example when you ask us to provide you with a product or service.
• Legal obligation – our use of your personal information is necessary to comply with a legal obligation that we have, for example where we are required to report to tax authorities.
• Public interest – our use of your personal information is required for regulatory reasons that are in the public interest, for example to prevent and detect financial crime.
How we share personal information within B2C2, with third parties and regulators
We may share your information in the manner and for the purposes described below:
• Within B2C2, where such disclosure is necessary to provide you with our services or to manage our business
• With third parties who help manage our business and deliver services. These third-parties have agreed to confidentiality restrictions and use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contractual service to us. These include IT service providers.
• With agencies and organisations working to prevent fraud in financial services
• With our regulators
• To comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies
• We may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our business partners, affiliates or advertisers
• B2C2 may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your personal information, technical information about your device or browser or other anonymous information we obtain from you via the website may be disclosed to any potential or actual third-party purchasers of such assets or may be among those assets transferred.
We may use personal information to let you know about B2C2 products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other helpful channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
To protect your privacy rights and ensure you have control over how we manage marketing with you:
• We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• You can ask us to stop direct marketing at any time. You can ask us to stop sending email marketing by following the ‘unsubscribe’ link you will find on the email marketing messages we send you.
We do not accept users under the age of 21 and no part of our website is structured to attract anyone under 21. In the event that we learn we have inadvertently collected personal information from an individual under the age of 21, we will take reasonable steps to delete that information. If you believe that we might have any information from an individual under 21, please contact us at firstname.lastname@example.org.
Your personal information may be transferred to, stored or processed in the United Kingdom, United States or any other country or jurisdiction in which B2C2 or its service providers maintain facilities or conduct business activities.
This may include a country and jurisdiction that does not have the same data-protection laws as your jurisdiction. For EEA and UK residents, your personal information may be transferred to a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law.
B2C2 will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests. To this end:
• Transfers within B2C2 will be covered by an agreement entered into by members of B2C2 which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within B2C2;
• Where we transfer your personal information outside B2C2, or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information.
You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.
We have implemented and maintain a comprehensive information security program with written policies and procedures designed to protect the confidentiality and integrity of personal information. The information security program contains administrative, technical and physical safeguards, appropriate to the type of information concerned, designed to:
• Maintain the security and confidentiality of such information;
• Protect against any anticipated threats or hazards to the security or integrity of such information;
• Protect against unauthorised access to or use of such information that could result in substantial harm; and
• Ensure appropriate disposal if such information.
The security of your personal information also depends in part on the security of the devices you use to communicate with us.
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting or necessary technical requirements.
In specific circumstances we may store your personal information for a longer period of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we believe there is a prospect of legal claims relating to your personal information or dealings.
Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the EEA or UK, and in certain other jurisdictions, you may have certain rights in relation to your personal information, these include:
• To access personal information – you have a right to request that we provide you with a copy of your personal information we hold and you have the right to be informed of:
— The source of your personal information;
— The purposes, legal basis and methods of processing;
— The data controllers identity; and
— The entities or categories of entities to whom your personal information may be transferred.
• To rectify or erase personal information – you have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information in limited circumstances where:
— It is no longer needed for the purposes for which it was collected; or
— You have withdrawn consent, where the data processing was based on consent); or
— Following a successful right to object; or
— It has been processed unlawfully; or
— To comply with a legal obligation to which B2C2 is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
— For compliance with a legal obligation; or
— For the establishment, exercise or defence of legal claims.
• To restrict the processing of your personal information – you can ask us to restrict your personal information, but only where:
— The accuracy is contested, to allow us to verify its accuracy; or
— The processing is unlawful, but you do not want it erased; or
— It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
— You have exercised the right to object and we are considering your request.
We can continue to use your personal information following a request for restriction:
— Where we have your consent; or
— To establish, exercise or defend legal claims; or
— To protect the rights of another natural or legal person.
• To transfer your personal information – you can ask us to provide your personal information to you in a structured, commonly use, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
— The processing is based on your consent or on the performance of a contract with you; and
— The processing is carried out by automated means.
• To object to the processing of personal information - you can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interest which override your rights and freedoms.
• To object how we use your personal information for direct marketing purposes – you can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to any unaffiliated third parties for the purposes of direct marketing or any other purposes.
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction – you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data agreements to protect commercial terms.
To lodge a complaint with your local supervisory authority – you have a right to lodge a complaint with your local data protection supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Under the California Consumer Privacy Act (“CCPA”), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the CCPA:
• To request more details about the personal information we collect about you – to request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months. This includes personal information disclosed for business purposes.
• To request deletion of your personal information – you may request that we delete certain pieces of personal information that we have collected about you.
• To opt-out of any “sales” of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.
• To not be discriminated against for exercising these rights.
California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales” even if no money is exchanged. We do not sell information to third parties as defined under California law. We do not knowingly sell the personal information of minors under 16 years of age.
California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will check the information you provide us in your request (which may include your name, phone number and email address) against third party identity verification tools or verified information you have previously provided to us. As part of this process, we may call you after you submit your request to verify information. You may also designate an authorized agent to exercise certain of the rights listed above on your behalf by providing the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.
If you are a California resident, you may exercise your rights by contacting us at the addresses provided below.
Processing your request
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.
We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will use reasonable efforts to honour your request promptly (and within any time period required by applicable law) or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
The primary point of contact for all issues arising from this privacy notice, including exercising your rights described above is our Data Protection Officer. The Data Protection Officer can be contacted in the following ways:
B2C2 Ltd, B2C2 OTC Ltd.
The Data Protection Officer
86–90 Paul Street
B2C2 USA, Inc, B2C2 Securities LLC, B2C2 Overseas Ltd.
The Data Protection Officer
101 Hudson St
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