This Privacy Statement describes Adroit Trading Technologies’ (“Adroit”, “we”, “us”, or “our”) practices regarding the use and disclosure of information about certain individuals that we collect and use when we run our business (referred to as “personal data”).

As part of our commitment to protect your personal data, we want to inform you:

• why and how ADROIT collects, uses and stores your personal data, for how long and under which legal basis;

• with whom we share your personal data;

• our role as the legal entity deciding about the processing of your personal data (referred to as the “controller”); and

• what your rights and our obligations are in relation to such processing.

1. Scope

This statement applies to any and all forms of use (“processing”) of personal data that you provide to us. Provisions where reference is made to the GDPR in this Privacy Statement apply when we act as a “controller” within the meaning of the GDPR (i.e. when ADROIT determines the purpose and the means for the processing of your personal data) in relation to personal data originating from or processed in the European Union.

2. Who

The individuals we collect personal data about are:

• the representatives of our prospects, customers, vendors, and suppliers;

• our prospective, current, and former employees;

• visitors of our website(s); and

• other individuals with whom we interact in the marketplace.

3. Types of personal data 

We collect and process identification information about all individuals with whom we interact, such as the name, title, position, company name, email and/or mailing address(es), and the professional business and/or mobile phone number(s) as well as information regarding any communications you may have with ADROIT. This information may either be directly provided by you or provided by the legal entity for whom you work.

For representatives of our customers, we also collect and process:

• identification information (e.g. current employer and past employer(s) if applicable);

• electronic identification data (e.g. login and password to access the products and services provided by ADROIT and data relating to the use of such products and services, such as those included in logs);

• information regarding the products and services ADROIT is providing to your employer; and

• information regarding your communications with ADROIT (e.g. your client manager, whether you can be contacted by mail, did you opt in to receive communications).

For candidates who apply for a job at ADROIT, as well as for our current and former employees, we also collect and process:

• further detailed identification information (such as date and place of birth, gender, picture, ID card and/or passport details, social security number, visa details, works permits, private email(s), and mailing address(es), private land-line and/or mobile phone number(s));

• electronic identification data (such as login rights, IP addresses, online identifiers/cookies, logs and connection times, and sound or image recordings);

• education and employment information (such as education, certifications, former employers’ names, locations and contact details, current and previous remuneration, bonus, pension entitlements, insurance and other benefits, expenses, travel expenses, employment dates, notes from recruiters, performance evaluations, results of knowledge tests, leave of absences, and language skills);

• financial information (such as bank account details, credit card numbers, and credit score); 

• information in relation to background checks (e.g. historical mailing addresses, information from public domain searches, international sanctions, presence or absence of criminal convictions); and

• family and other relatives’ information (such as marital status, number and dates of birth of children, name of emergency contact and contact details, and beneficiaries).

For our website visitors, we collect and process:

• electronic identification data (e.g. your user id and password, your device identifier and your IP address);

• technical information (e.g. type and version of your browser and your operating system, information regarding the pages you visit, information researched, time spent on our website, and other statistics regarding your browsing experience on our website); and

• information regarding your preferences on our website.

You may participate in public forums on our websites, such as commenting on a posting or submitting questions, responses, or other content. Any information you post will be publicly viewable on the website as soon as that information is submitted, and could be used by others to send you unsolicited communications. Please be careful about disclosing information in public forums. Our website also contains links to other websites that are not owned by ADROIT. Please note that these other websites’ privacy statements may differ from that of ADROIT. We recommend that you read the privacy statement of any website you may visit because we are not responsible for such websites’ content or policies.

To the extent authorized by law, we may also process so-called sensitive data, such as health related data. ADROIT will only do so as strictly required to comply with its legal obligations and to enable you to obtain benefits and, where necessary, with your prior consent. In such case, the data will be accessed and processed solely under the responsibility of a representative of ADROIT who is subject to an obligation of confidentiality.

Whenever personal data is collected, we will indicate whether the provision of such data is mandatory and the consequences of a refusal in providing the requested data.

4. Processing Responsibility

Adroit Trading Technologies, LLC., a company incorporated under the laws of the United States of America, with registered offices at 175 Atlantic Street, STE 200, Stamford, CT, USA is responsible, as controller, for the processing of your personal data.

5. Legal Basis & Purpose 

a. Legal basis 

Where required by applicable data protection law, including the GDPR, we will only process your personal data where:

• such processing is necessary to comply with our legal or regulatory obligations; or

• such processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request; or

• we have obtained your prior consent; or

• such processing is necessary to protect your vital interest; or

• such processing is necessary for the legitimate interest of ADROIT to the extent it is not overridden by your own interest or fundamental rights and freedom.

In relation to the processing of your personal data, our legitimate interests are:

• to benefit from cost-effective services;

• to offer our products and services to our customers via their representatives;

• to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks; and

• to meet our corporate and social responsibility objectives.

b. Purpose

How we use information we collect about you depends, in large part, on the purpose for which it is provided to us. We process your personal data for specific purposes and only to the extent relevant to achieve these purposes. In particular, we process your personal data for the following purposes:

In relation to our prospective, current, and former employees:

• for recruitment and onboarding;

• for the purpose of pre-employment and annual background checks;

• to manage our personnel (including benefits and absence management);

• for training purposes;

• to manage our payroll;

• to manage our HR records;

• to carry out performance reviews;

• to monitor our employees’ activities in the workplace, including compliance with our internal policies, IT security as well as health and safety rules in place;

• to manage our IT resources, including infrastructure management & business continuity;

• to handle internal complaints relating to violence, moral harassment and misconduct;

• for disciplinary action;

• to reply to an official request from a public or judicial authority in compliance with legal requirements; and

• to comply with any legal obligations imposed on ADROIT in relation to its employees.

In relation to representatives of our prospects, customers, vendors and suppliers

• to undertake marketing/procurement activities relating to our products;

• to manage our customers, vendors, and suppliers;

• to implement tasks in preparation of or under existing contracts;

• to provide our products and services;

• for invoicing purposes;

• to monitor activities at our facilities, including compliance with our applicable policies, IT & other security related internal rules, and health & safety rules;

• to manage our IT resources, including infrastructure management & business continuity;

• to manage our archiving and records;

• to track our activities (measuring sales, number of calls, visits to our website, etc.);

• to improve our existing or upcoming products and services;

• to improve the quality of services to our clients by taking into account their preferences in terms of means of communication, frequency, and otherwise;

• to preserve our economic interests;

• to reply to any official request from a public or judicial authority in compliance with legal requirements;

• more generally, to comply with any legal, accounting and tax obligations imposed on ADROIT in its relation with its customers, vendors, and suppliers; and

• to periodically send promotional emails about our products, special offers and information which you or your company may find interesting, using the contact information which you have provided (if any).

In relation to website visitors

• to manage and improve our website;

• to measure the usage of our website (including drawing up statistics);

• to manage users (such as account management and answering questions).

6. Access & Sharing

We do not share your personal information with companies, organizations, or individuals outside of ADROIT except in the following cases:

a. With your consent

We’ll share personal information outside of ADROIT when we have your consent. We’ll always ask for your explicit consent to share any sensitive personal information.

b. For external processing

We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Statement and any other appropriate confidentiality and security measures. These can include our (IT) systems, cloud service, data centers and database providers, our payroll provider; benefits providers, competent authorities and HR related services providers.

c. For legal reasons

We will share personal information outside of ADROIT if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, legal process, or enforceable governmental request.

• Detect, prevent, or otherwise address fraud, security, or technical issues.

• Protect against harm to the rights, property or safety of ADROIT, our users, or the public as required or permitted by law.

We do not transfer personal data to third parties for commercial use without your explicit consent.

7. Minors

Our websites, products, and services are not directed at minors. We do not knowingly collect personal data from children under the age of 18. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us by clicking on the Contact Us button at the top of this page and we will take steps to delete such personal data from our systems.

8. Storage

We will only retain personal data for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Employee data is kept for 7 years post-termination, after which they are destroyed, unless overriding legal or regulatory schedules require a longer or shorter retention period.

Personal data we hold in relation to candidates who applied for a position at ADROIT will be kept for 5 years after the last contact with ADROIT.

Personal data processed in the context of a dispute are deleted (i) as soon as an amicable settlement has been reached, (ii) once a decision of last resort has been rendered and enforced or (iii) when the claim becomes time barred, except as otherwise specified in the preceding paragraphs.

We hold the personal data collected in the framework of ADROIT’s website for a period of 1 year following the last visit to our website.

When the above periods expire, your personal data will be removed from our systems, but some data may still be processed following such deletion or return request due to technical constraints (e.g. use of back-ups and e-mail archives).

9. Your Rights

a. Your Rights

Within the limits and under the conditions set forth therein, you have the following rights:

• to access your personal data as processed by us and obtain a copy thereof;

• to request any correction or update thereof;

• to request the erasure of your personal data;

• to request the restriction of the processing of your personal data;

• to object to the processing of your personal data;

• to withdraw your consent where ADROIT based its processing of your personal data on your consent (without such withdrawal affecting the lawfulness of processing prior thereto);

• to request the portability of your personal data.

b. Exercising your rights

To exercise the above rights, you may send a request by email to ops@adroit.com, with a scan/copy of your drivers license or passport for identification purposes. We will respond in compliance with applicable law. If you are not satisfied with how ADROIT processes your personal data, please let us know and we will investigate your concern. You also have the right to make a complaint to the competent data protection authority.

10. Cookies

Cookies are small text files that are sent to your computer when you visit our website. ADROIT and certain service providers operating on our behalf may use cookies and similar technologies such as web beacons, pixel tags, or other passive tracking methods. We do not use such methods to track individual visitors or to identify you but to automatically collect statistics about your activity on the website or to complete the purposes set out above, in accordance with this Privacy Statement.

Personal data generated through cookies are collected in a pseudonymised/anonymised form and subject to your right to object to such data processing, as set out below. 

Please note that you can modify your browser so that it notifies you when cookies are sent to it. If you do not want to receive cookies, you can also refuse cookies altogether by activating the relevant settings on your browser. Finally, you can also delete cookies that have already been set. However, you may not be able to complete certain activities or access certain information on this website if cookies are disabled. In addition, service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.

For more information as to how to manage cookies on your device, please consult the Help function of your browser or visit www.aboutcookies.org, which contains comprehensive information on how to do so on a wide variety of browsers.

11. Updates & Amendments

We change this Privacy Statement from time to time. We will not reduce your rights under this Privacy Statement without your explicit consent. We always indicate the date the last changes were published. If changes are significant, we’ll provide a more prominent notice.