Eiger Trading Advisors
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Privacy Policy

This is our website privacy policy.

This privacy policy provides information on how we collect and process your personal data when you visit and/or use our website.

This policy was last updated 1 April 2020.

Important information and who we are

Eiger Trading Advisors Limited (“Eiger” / “we” / “us” / “our” ) is the controller and responsible for your personal data.

If you have any questions about this privacy policy or our data protection practices please contact us using the details below:

Full name of legal entityEiger Trading Advisors Limited
Name or title of responsible personData Privacy Manager
Email addressdataprotection@eigertrading.com
Postal addressRiverbridge House, Guildford Road, Leatherhead, Surrey KT22 9AP, United Kingdom

We keep our privacy policy under regular review. This version was last updated on 2 April 2020.

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.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

    • Identity Data, which includes first name, last name, title, job title and name of the organisation you represent or for which you work.
    • Contact Data, which includes postal address, email address and telephone numbers.
    • Technical Data, which includes internet protocol (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
    • Usage Data, which includes information about how you use our website, including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). To learn more about our use of cookies or similar technology please check our Cookie Policy.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

What we do with the information we gather

Direct interactions: you may give us your Identity Data and Contact Data by filling in the form on the Contact Us section of the website. This includes personal data you provide when you:

    • ask us to contact you or respond to an enquiry from you
    • give us feedback or contact us
    • request marketing information to be sent to you

Automated technologies or interactions: as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [LINK] for further details.

Third parties: we will receive Technical Data from analytics providers such as Google, based outside the UK.

How we use your personal data

Except where we need to comply with a legal obligation, we will only use your personal data for the purposes for which we collected it, which include the following:

to contact you in response to an enquiry or request for marketing or other information

to improve our website, products/services, marketing or customer relationships

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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those rights
    • where we need to comply with a legal obligation
    • where we have obtained your consent

These terms are explained in more detail in the section below headed “Glossary: lawful basis”

We have set out below, in table format, a description of all the ways we plan to use your personal data and the lawful bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying upon to process your personal data where more than one lawful basis has been set out in the table below.

Purpose/ActivityType of dataLawful basis of processing (including basis of legitimate interest)
To respond to enquiries or requests for marketing and other information
  • Identity
  • Contact
  • Necessary for our legitimate interests (for responding to enquiries about our business)
To administer and protect this website
  • Technical
  • Necessary for our legitimate interests (for provision and administration of a website to provide information about our business, network security)
  • Consent, in the case of personal data that we collect by means of optional cookies which we obtain your consent to use
To deliver relevant website content and measure or understand the effectiveness of the website as a means of providing information.
  • Technical
  • Usage
  • Necessary for our legitimate interests (to study how visitors to our website use the site and what information they access; to keep our website updated and relevant; to form a view on what we think visitors to the website may want or need, or what may be of interest to them, in order to inform our marketing and communication strategy)
  • Consent, in the case of personal data that we collect by means of optional cookies which we obtain your consent to use.
To use data analytics to improve our website, products/services, marketing, and customer relationships and experiences
  • Technical
  • Usage
  • Necessary for our legitimate interests (to study how visitors to our website use the site and what information they access; to keep our website updated and relevant; to form a view on what we think visitors to the website may want or need, or what may be of interest to them, in order to inform our marketing and communication strategy)
  • Consent, in the case of personal data that we collect by means of optional cookies which we obtain your consent to use
To take professional advice in connection with our business
  • Identity
  • Contact
  • Technical
  • Usage
Necessary for our legitimate interests (to obtain professional advice in connection with our business)

How we share your personal data

We may share your personal data within the company and with various third parties for the purposes set out in the table above. Further details of the third parties with which we share your personal data are given below.

    • Service providers (acting as processors) based in the UK and elsewhere who provide IT, system administration and other services, including:
          • website design and hosting (WordPress)
          • data hosting (Amazon Web Services)
          • analytics (Google Analytics)
          • customer relationship management system (Salesforce)
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and elsewhere who provide consultancy, banking, legal, insurance and accounting services.
    • Regulators and other governmental authorities acting as processors or joint controllers based in the United Kingdom and elsewhere who may require reporting of processing activities in certain circumstances

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.

International transfers

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you, please write to Eiger Trading Advisors Ltd, Riverbridge House, Guildford Road, Leatherhead, Surrey, UK KT22 9AD.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

How we keep your personal data secure

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.

How long we keep your data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are described below:

    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
            • if you want us to establish the data’s accuracy.
            • where our use of the data is unlawful but you do not want us to erase it.
            • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
            • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details given above.

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 could 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 could 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.

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

Glossary: lawful basis

Legitimate Interest means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means processing your personal data where by some positive act you have freely given your specific informed consent, which you may withdraw at any time.