This policy was last updated 1 April 2020.
Eiger Trading Advisors Limited (“Eiger” / “we” / “us” / “our” ) is the controller and responsible for your personal data.
|Full name of legal entity||Eiger Trading Advisors Limited|
|Name or title of responsible person||Data Privacy Manager|
|Postal address||Riverbridge House, Guildford Road, Leatherhead, Surrey KT22 9AP, United Kingdom|
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.
We may collect, use, store and transfer different kinds of personal data about you as follows:
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:
Third parties: we will receive Technical Data from analytics providers such as Google, based outside the UK.
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:
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/Activity||Type of data||Lawful basis of processing (including basis of legitimate interest)|
|To respond to enquiries or requests for marketing and other information|
|To administer and protect this website|
|To deliver relevant website content and measure or understand the effectiveness of the website as a means of providing information.|
|To use data analytics to improve our website, products/services, marketing, and customer relationships and experiences|
|To take professional advice in connection with our business||Necessary for our legitimate interests (to obtain professional advice in connection with our business)|
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.
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.
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.
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.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are described below:
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.
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.