Amplify Trading Limited takes data privacy very seriously and to demonstrate our strong commitment to protecting personal data we have detailed our policy protocols below, including important information on who we are and how and why we collect, store, use and share your personal information, in relation to our simulation services (‘Simulations’).
This policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event that you have a complaint. If you have any comments regarding the policy, please get in touch with us at email@example.com or on +44 (0) 203 372 8415
We collect, use and are responsible for certain personal information about you. When we do so we are subject to data protection legislation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
2. ABOUT US
Amplify Trading Limited (‘Amplify Trading’, the ‘Company’, ‘we’) is a registered company in England and Wales (No. 06798566).
As we endeavour to respect individual’s privacy as far as practically possible, we encourage you to check back to this page from time-to-time to review the latest version of the policy.
3. WHAT DATA WE COLLECT
We may collect and use the following forms of personal information about you when you participate in a Simulation(s):
• Personal details: name, email and telephone number
• Performance data and behavioural metrics relating to your participation in a Simulation(s)
• If, and what date, you would like to attend a Simulation(s)
• How you heard about Amplify Trading
• Country of residence
• Native language
• Preferred region of employment
• Name of university or institution
• Year of graduation
• University course name
• University course type
• Level of study
• Your current coding ability (if any)
• Simulation performance metrics
4. HOW WE GATHER YOUR DATA
We collect all personal information directly from you – when you make an enquiry, or on our website when you download a brochure, or as part of the registration process to take part in a Simulation
5. HOW AND WHY WE USE YOUR DATA
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
6. WHAT WE USE YOUR PERSONAL INFORMATION FOR
Your attention is particularly drawn to this clause
To share your personal information to Financial Institutions in accordance with the ‘Who we share your personal information with’ section below.
Where you have provided your opt-in consent for us to share your personal information to Financial Institutions.
To provide our services to you in relation to one of our Simulations
For the performance of our contract with you (where we contract with you in order to provide a Simulation) or take steps at your request before entering into a contract.
Operational reasons, such as:
• improving efficiency, training and quality control;
• to ensure information on our website is presented as clearly and effectively as possible; and
• to assess and understand our client’s feedback.
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you and our clients at the best price (where relevant).
To promote our Trading Courses to you by email
Where you have provided your opt-in consent to receive information about further training opportunities
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures
Preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating customer records
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about current services being provided and new services
To comply with our legal and regulatory obligations
We will only send you marketing communications where you have provided your opt-in consent. The only marketing communications we send are about our content, training courses and Simulations and you will always be given the opportunity to opt-out of receiving further communications. If you wish to subscribe to our marketing newsletter then you can opt-in (HERE) or when signing up for our services, and you can unsubscribe at any time by following the instructions in the newsletter.
If you contact us via email, telephone, post, or online enquiry, we will contact you with non-promotional communications, including necessary information regarding the products and services you enquired about, in order to facilitate entry into the contract of using our services.
We will never share your data with any third-party for marketing purposes, without having your explicit permission to do so.
Who we share your personal information with
We routinely share personal information with:
• Service Providers: third parties we use to help deliver our services to you, eg payment service providers;
• Additional Service Providers: other third parties we use to help us run our business, eg website hosts;
• Linked Service Providers: third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• Insurers: our insurers and brokers;
• Banking Providers: our bank;
• Financial Institutions: Where you sign-up to use our Simulations we may also share your personal information with our financial institution partners if you have provided your consent to do so, as described in the ‘How and why we use your data’ section above. An example of some of our financial institution partners are as follows:
◦ Morgan Stanley
◦ Credit Suisse
◦ Bank of America Merrill Lynch
We only share information with Financial Institutions in relation to your performance if you have performed above a certain performance threshold, as agreed with the Financial Institutions. Financial Institutions use this information to identify potential candidates for employment. We only allow our service providers and Financial Institutions to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
• External Auditors: We may also share personal information with external auditors, eg in relation to the audit of our accounts.
• Law Enforcement/Regulatory: We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
• Business Sale/Restructure: We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7. WHERE IS YOUR INFORMATION HELD
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
8. HOW LONG DO WE KEEP YOUR DATA
‘We’ will keep your data for a reasonable period of time in order to facilitate your enquiry in regards to one, or more, of our courses.
9. HOW WE PROTECT AND STORE YOUR DATA
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online and in person at workshops or trade fairs.
10. TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE UK OR EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK or European Economic Area (EEA), eg: with our service providers located outside the UK or EEA.
These transfers are subject to special rules under European and UK data protection law. We will ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information please contact us (see ‘Contact us’ below).
11. CHANGES TO THIS POLICY
12. KNOW YOUR OWN RIGHTS
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal information (the right of access)
The right to require us to correct any mistakes in your personal information
• To be forgotten
The right to require us to delete your personal information - in certain situations
• Restriction of processing
The right to require us to restrict processing of your personal information - in certain circumstances, eg if you contest the accuracy of the data
• Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations
• To object
The right to object
• at any time to your personal information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
• Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to us - see below: ‘Contact us’; and
• provide us with enough information to identify you (eg your full name and address);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
13. CONTACT US
We want you to remain in control of your own personal data. If, at any time, you want to update or amend your personal data or communication preferences, please contact us on firstname.lastname@example.org or +44 (0) 203 372 8415.
Data protection legislation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted telephone: 0303 123 1113