# Privacy Policy ## Introduction Welcome to OTCX Group ("we," "us," "our"). We are committed to protecting and respecting the privacy of our customers, users of our website, suppliers, individuals who contact us, and those other external parties whose personal data we may otherwise process in the course of our business ("you" and "your"). This policy outlines how we collect, use, disclose, and safeguard your information when you visit our website [www.otcxtrading.com](/content/site-root.html) or engage with our services. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. In this privacy policy, "Data Protection Legislation" means the UK Data Protection Act 2018 and GDPR 2016/679; together with all other applicable legislation relating to privacy or data protection and the terms "personal data", "data subject", "controller", "processor" and "process" (and its derivatives) shall have the meanings given to them in the Data Protection Legislation. ## Information We Collect ### Personal Data We may collect and process the following personal data about you, which means information that can be used to identify you, including (but not limited to) the following types of personal information: - **Identity Data:** Name, username or similar identifier, marital status, title, date of birth, and gender. - **Contact Data:** Billing address, delivery address, email address, and telephone numbers. - **Financial Data:** Bank account details. - **Transaction Data:** Details about payments to and from you and other details of services you have purchased from us. - **Technical Data:** IP address, 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:** Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. - **Usage Data:** Information about how you use our website, products, and services. - **Marketing and Communications Data:** Your preferences in receiving marketing from us and your communication preferences. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. ### Special Categories of Data We do not typically collect special categories of personal data about you (e.g., race, ethnicity, religious beliefs, sexual orientation, political opinions, health data, or criminal records). ### Third Party Information If any information which you provide to us relates to any third party, by providing us with such personal information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with the above provisions, or are otherwise permitted to give us this information. You further agree to make such third parties aware of this privacy policy. ## How We Collect Your Data We use different methods to collect data from and about you, including: - **Direct interactions:** You may provide data by filling in forms or by corresponding with us by post, phone, email, or otherwise. - **Automated technologies or interactions:** As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. - **Third parties or publicly available sources:** We may receive personal data about you from various third parties and public sources. ## How We Use Your Data ### Processing 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: - **Performance of Contract:** Where we need to perform the contract we are about to enter into or have entered into with you. - **Legitimate Interests:** 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. - **Legal Obligations:** Where we need to comply with a legal or regulatory obligation including anti-money laundering and anti-terrorist financing (collectively "AML") and fraud prevention purposes. Purposes for which we will use your personal data include: - To manage our relationship with you. - To manage payments, fees, and charges. - To improve our website, services, marketing, and customer relationships and experiences. - To prevent fraud. - To protect our business interests. - To ensure that complaints are investigated. - To evaluate, develop or improve our products and services. - To keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so. - For any other specific purposes where you have given specific consent to that processing for those purposes. ### Automated Processing When we use your information, we may use automated processes. In particular, in order to comply with our obligations under AML legislation, we are required to verify the identity of all clients and other information (including but not limited to details of any nationality, citizenship or rights of residence you hold). If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk: - We may refuse to provide the services you have requested, or we may stop providing existing services to you; - A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Generally, we do not rely on consent as a legal basis for processing your personal data. Where we have asked for your consent and you have given it, you have the right to withdraw it at any time by contacting us. You always have the right to unsubscribe from any direct marketing that you receive from us. ## Disclosure of Your Data We may share your personal data with: - **Service providers:** Acting as processors who provide IT and system administration services. - **Professional advisers:** Including lawyers, bankers, auditors, and insurers. - **HM Revenue & Customs, regulators, and other authorities:** Acting as processors or joint controllers. - **Any other person or organisation** after a restructure, sale or acquisition of any OTCX Trading Limited company. - **Your advisers** (including, but not limited to, accountants, lawyers or other professional advisers) where authorised by you. 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. ## 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. ## Data Retention We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. ## Your Legal Rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: - Request access to your personal data. - Request correction of your personal data. - Request erasure of your personal data. - Object to processing of your personal data. - Request restriction of processing your personal data. - Request transfer of your personal data. - Withdraw consent. If you wish to exercise any of the rights set out above, please contact us at [dataprivacy@otcxtrading.com](mailto:dataprivacy@otcxtrading.com) and we will respond within one month. ## Use of Closed Circuit Television OTCX operates Closed‑Circuit Television (CCTV) systems at certain office premises for the purposes of security and safety. ### Purpose of Processing CCTV is used to: - Protect employees, visitors and contractors; - Safeguard OTCX premises and assets; - Deter, prevent and investigate unauthorised access or criminal activity; and - Support the investigation of security, health and safety, insurance or legal incidents where necessary. CCTV is not used for routine monitoring of employees or for performance or disciplinary purposes. ### Scope and Operation CCTV cameras are installed only in appropriate locations, such as entrances, exits and communal areas. ### Lawful Basis The lawful basis for processing personal data via CCTV is legitimate interests under Article 6(1)(f) UK GDPR. ### Access and Disclosure Access to CCTV footage is restricted to authorised personnel and is permitted only where there is a legitimate and proportionate need. ### Retention CCTV footage is retained for a limited and proportionate period and is securely deleted once no longer required. ### Data Subject Rights Individuals whose images are captured by CCTV have rights under data protection law. ### Governance and Review The use of CCTV is subject to appropriate governance and periodic review. ## Cookies Some of your personal data that we process may consist of cookies, which are small text files that often include a unique identifier. For details of how we deal with cookies, please see our [Cookie Policy](/content/terms/index.html). ## Marketing Communications We may use your information to inform you about similar products and services (including those of third parties) which may be of interest to you. You may, at any time, request that we do not send such information. ## Changes to This Policy We keep our privacy policy under regular review. Any changes will be posted on this page. ## Contact Us If you have any questions about this Privacy Policy or our privacy practices, please contact us at: Email: [dataprivacy@otcxtrading.com](mailto:dataprivacy@otcxtrading.com) Postal Address: 6 Dowgate Hill, London, EC4R 2SU, United Kingdom.