Innovative Trading

This Privacy Policy explains how we use the Personal Data that is collected or generated in connection with your engagement with our systems and individuals, as well as with third parties.

The list below sets out what is covered in this Privacy Policy. You can click on the headings below to go to a specific section.

1. BACKGROUND
2. THE TYPES OF PERSONAL DATA WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
6. HOW WE SAFEGUARD YOUR INFORMATION
7. HOW LONG WE KEEP YOUR PERSONAL DATA
8. YOUR RIGHTS
9. DESIGNATED REPRESENTATIVE
10. QUESTIONS AND CONCERNS

BACKGROUND

Should you decide to send us any Personal Data, for example if you apply for an open role or via email or other communications with us, we will collect and use such Personal Data in accordance with this Privacy Policy. We are responsible for ensuring that we use that Personal Data in compliance with data protection laws. We may also collect some limited Personal Data through other means, for example from publicly available sources, third parties, or through CCTV at our premises.

We respect privacy and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data in connection with interactions and communications with us.

We use the following definitions in this Privacy Policy:

“we” or “us” means STG Management (DIFC) Limited. A full list of the entities that process your Personal Data can be obtained by contacting us using the information set out in Section 10 below.

“Personal Data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with, directly or indirectly, a particular living individual or household and other personal information which is in our possession of, or is likely to come into our possession. In addition to factual information, it includes any expression of opinion about an individual and any indication of our intentions or any other person in respect of an individual.

THE TYPES OF PERSONAL DATA WE COLLECT

In relation to communications and interactions with us, we may collect and process the following Personal Data about you:

• Information that you provide. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. Such information may include (by way of a non-exhaustive list):
  • your name, postal address, e-mail address, telephone number, educational background, employment history, and any other information contained within your resume and business contact details; and
  • records and copies of your correspondence with us if you contact us.
• Information that we collect or generate about you. This includes (by way of non-exhaustive list):
  • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the responses which we have provided to you;
  • a record of your application for a position, if you submit such an application. The Personal Data that we process in connection with any such application will be treated in accordance with our Applicant Privacy Notice;
  • certain information that is provided by the cookies that we use;
  • electronic communication data;
  • information about your computer and internet connection, including your IP address, operating system, browser type, etc.;
  • CCTV footage if you visit our premises; and
  • other information you or others may provide to us during your communications or relationship with us.
• Information we obtain from other sources. This includes limited publicly available information we collect directly or indirectly. We may also collect some data from third party vendors.
• Anonymized data. In addition to the categories of Personal Data described above, we may also process anonymized information and data that is not processed by reference to a specific individual.

HOW WE USE YOUR INFORMATION

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to consider you for a position, if you have contacted us to apply for such a position, in which case your Personal Data will be treated in accordance with our Applicant Privacy Notice;
• in order to respond to your queries and to provide you with products and/or services or information about them upon your request;
• for in-depth threat analysis;
• in order to comply with, and in order to assess compliance with, applicable laws, rules and regulations;
• for security purposes in relation to CCTV;
• for business analysis and development of products and services;
• for the administration and maintenance of databases storing Personal Data; or
• for our general operational or business purposes.

We use Personal Data for a variety of reasons. These include:

• performing our contractual obligations with customers and other third parties;
• satisfying legal and regulatory obligations;
• establishing, exercising, or defending our legal rights or for the purpose of legal proceedings; or
• the use of your Personal Data as described may be necessary for our legitimate business interests, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our business;
  • monitoring the use of our copyrighted materials;
  • responding to correspondence that we receive;
  • enabling quick and easy access to information on our products and services; and
  • maintaining the security of our networks and IT systems and our physical premises.

We collect and process personal data about our suppliers, vendors (including trading counterparties), and their representatives in order to manage the relationship, to contract with them, and to receive services from them.

We take steps to ensure that the Personal Data is accessed only by employees that have a need to do so for the purposes described in this Privacy Policy.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We may share your Personal Data with affiliates for the purposes described above.

We may also share your Personal Data with non-affiliates for the following purposes:

• with our business partners for various purposes. For example, this could include our partners from whom you or your company or organisation purchased our products or services. We take steps to ensure that Personal Data is only transferred to business partners that are contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, our professional advisors, and IT and communications providers). We take steps to ensure these third parties are contractually obliged to comply with appropriate data protection obligations and to only use your Personal Data as described in this Privacy Policy;
• to the extent required by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
• with police and law enforcement in the event of a security or other investigation that necessitates their involvement;
• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We are a multinational business. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

Where we transfer your Personal Data to from within the EEA to another country outside the EEA, we take steps to ensure that it is protected and transferred in a manner consistent with legal requirements. This may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed a contract based on “standard contractual clauses” approved by the European Commission, obliging the recipient to protect your Personal Data; or
• in other circumstances, the law may permit us to otherwise transfer your Personal Data outside the EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described in Section 10 below.

HOW WE SAFEGUARD YOUR INFORMATION

We have certain controls in place designed to maintain the security of our information and information systems, including controls designed to protect Personal Data with safeguards according to the sensitivity of the relevant information and controls (such as restricted access) placed on our computer systems. We take steps to ensure physical access to areas where Personal Data is gathered, processed, or stored is limited to authorised employees.

As a condition of employment, our employees are required to follow all applicable laws and regulations, including in relation to data protection. We take steps to ensure access to Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures.

When you contact an employee about your file, you may be asked to provide some Personal Data for verification purposes. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

HOW LONG WE KEEP YOUR PERSONAL DATA

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

YOUR RIGHTS

In certain of the above cases in which we collect, use, or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided deliberately to us;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;
• the right to object to the use of your Personal Data for direct marketing purposes; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed in Section 10 below.

DESIGNATED REPRESENTATIVE

Our registered office and designated representative may be contacted using the following contact information:

Email Address: stg-dataprotection@squarepoint-trading.com

QUESTIONS AND CONCERNS

If you have any questions or concerns about our handling of your Personal Data, or about this Privacy Policy, please contact us using the following contact information:

Email Address: stg-dataprotection@squarepoint-trading.com

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.