Aquis Exchange Plc Website Privacy Policy

Introduction

Welcome to the Privacy Policy of Aquis Exchange PLC (Aquis).

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

Please note that terms in italics are defined in the Glossary

The Policy contains the following information:

1 Important information and who we are
2 The data we collect about you
3 How is your personal data collected?
4 How we use your personal data
5 International transfers
6 Data security
7 Data retention
8 Your legal rights
9 Glossary

Important information and who we are

Purpose of this privacy statement

This privacy statement provides information on how Aquis collects and processes your personal data through your use of this website, including any data you may provide through this website, for example when you contact us, access our services, platforms, events, software, platforms (including third-party platforms that host our content) (collectively referred to as “services”) or request information about our Exchange.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy statement together with any other privacy statement or fair processing statement we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.

Our Services

For certain services, Aquis Exchange (collectively referred to as "we", "us" or "our" in this privacy statement) decides how it uses your personal data (making it the one in charge of handling your data).

For other services, we only use your personal data as our customers tell us to (making us just the ones carrying out their instructions).

When acting as controller, we oversee handling persona data for the services we offer, unless we specifically say otherwise. For more information about what we offer, please visit: www.aquis.eu.

This privacy statement does not apply when we are acting in the role or capacity of a processor or service provider (or any other similar role or capacity) of personal data on behalf of a third party. In such case, we are processing personal data at the direction and instruction of the third party and the third party’s privacy statement(s) will govern and control.

If you have any questions about this privacy statement, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.

Aquis Exchange PLC Floor 2, 63 Queen Victoria Street, London, EC4N 4UA

Phone: 020 3597 6311

Email: legal@aquis.eu

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.

Changes to the privacy statement

We keep our privacy statement under regular review. This version was last updated in March 2024.

Third-party links

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 statement of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data).

We may collect, use, store and transfer different categories of personal data about you, depending on the services you use or your interactions with us, which we have grouped together as follows:

Identity data includes first name, last name, username or similar identifier, title, job title.
Contact data includes postal address, email address and telephone numbers.
Technical data includes internet protocol (IP) address, login data, 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 includes your username and password, your interests, preferences and feedback.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical 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 statement.
We may collect certain categories of sensitive personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may also collect any information about criminal convictions and offences.
We may obtain personal data beyond what’s mentioned above from various public sources. These sources may include information publicly available on the internet, widely distributed media, or records from government agencies. Examples of such information range from sanction lists to public records on governmental websites, and even personal data shared on social media platforms. This public source data may include details like age, race, political opinions, and more.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
request a contact from our sales team;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback or contact us.
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 and other similar technologies, for example from analytics providers such as Google, based outside the UK. Please see our cookie policy for further details.
Identity and Contact Data from data brokers or aggregators.

How we use your personal data

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 interests.
Where we need to comply with a legal obligation.

Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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

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

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To respond to a request from you for further information about our services	(a) Identity (b) Contact	Consent
To manage our relationship with you which may include: (a) Notifying you about changes to our terms or privacy statement (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website. See ‘Cookies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

We will never sell or share your personal data with other organisations outside Aquis Exchange Plc for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at marketing@aquis.eu.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a request for further information or use of a product/service or other transaction.

Cookies

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested, such as storing your preferences.

You can withdraw any consent to the use of cookies or manage any other cookie preferences by clicking on the “cookie preferences” icon at the bottom of any page on our site. You can then update your preference by clicking the related toggle button and saving your update. Your preference will be remembered for a year.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

We may store and process your personal data outside of your home country, where data protection laws may not offer the same level of protection. We have measures in place to ensure that your personal data, when transferred internationally, is subject to appropriate safeguards as required by data protection laws.

When we transfer personal data internationally, we implement safeguards in accordance with applicable laws, including Articles 44 to 50 of the EU General Data Protection Regulation. If you wish to learn more about our data transfer practices, please contact us using the information provided above.

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. In addition, we limit access to your personal data to those employees, 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.

Data retention

How long will you use my personal data for?

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.

Your legal rights

Under certain circumstances, you as a data subject have rights under data protection laws in relation to your personal data. Please refer to the Glossary to find out more about these rights.

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.
Right to withdraw consent.

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

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business 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.

YOUR LEGAL RIGHTS

You have the right to:

9.1. 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.
9.2. 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.
9.3. 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.
9.4. 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.
9.5. 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.

9.6. 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.
9.7. 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.