Privacy Policy
Introduction to this Website Privacy Policy
This website (the "Site") is owned and operated by FLEX GLOBAL TRADING LLC ("FLEX GLOBAL TRADING"). At FLEX GLOBAL TRADING, we recognize the importance of privacy to you and are firmly committed to protecting your privacy when you visit the Site and provide information to us. As a result, we have instituted this website privacy policy ("Privacy Policy"). FLEX GLOBAL TRADING is providing this Privacy Policy to explain how we collect, use, disclose and protect the Personal Data you submit to us when accessing and using the Site, including when you apply to work with us (for example, through our ‘Careers’ page). FLEX GLOBAL TRADING is the controller within the meaning of applicable data protection laws. As used in this Privacy Policy, "we," "our" and "us" means FLEX GLOBAL TRADING and its affiliates.
Important notice about international transfers
Due to the global nature of our business, your Personal Data will be stored and transferred to parties located in other countries, including outside the UK and European Economic Area (“EEA”), for example, when shared with a CCI group affiliate outside the UK or EEA or when one of our service providers use staff or equipment based outside the UK and EEA. In particular, we store your Personal Data on servers in the United States of America.
These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. Where UK or EU data protection laws apply, certain countries may not be deemed by the UK Information Commissioner’s Office or European Commission (as applicable) as providing adequate protection for Personal Data. Where that is the case, we have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights. In such cases, we implement appropriate safeguards to ensure an adequate level of protection for your Personal Data, such as by entering into standard contractual clauses (“SCCs”) or other mechanism recognized under applicable data protection laws.
If you have any questions, please contact us. Please note commercially sensitive information may be removed/blanked out from copies supplied to you.
The categories of Personal Data we may collect, the purpose and the lawful basis
Personal Data collected from you include the following:
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Criminal convictions and offences:
Where appropriate, and in accordance with applicable data protection laws, we may collect information about criminal convictions and offences from selected candidates from your responses to our disclosure questionnaire(s)) or otherwise as part of our background checks during the recruitment process.
Such processing is carried out: where it is necessary for the purposes of performing or exercising obligations or rights in connection with employment; where there is a substantial public interest, such as prevention or detection of unlawful acts, protection of the public from dishonesty or fraud, or regulatory compliance; or for the establishment, exercise or defense of legal claims.
Where required under applicable data protection laws, this processing is subject to an appropriate policy document and additional safeguards.
Special categories of Personal Data:
Some of the Personal Data that you may provide (including information about race, ethnicity, religious beliefs, political opinions, or health condition (e.g. disability and/or long-term health conditions), sexual orientation) is treated as “special categories” of Personal Data to which additional protections apply under applicable data protection laws.
Such processing may be justified by your explicit consent; the necessity of processing to carry out obligations and exercise rights under employment law (e.g. to make reasonable workplace adjustments); our legitimate interest in monitoring diversity and promoting equality (on the basis of substantial public interest grounds); the establishment, exercise or defense of legal claims.
We ensure such processing is limited to what is necessary and handled in accordance with applicable law and internal policies.
Summary:
In summary, we process Personal Data where necessary to: administer contractual relationships; comply with our legal and regulatory obligations; pursue our legitimate interests (where these are not overridden by your interests or fundamental rights); or where you have provided your explicit consent.
Where required by law, we implement additional safeguards for special category and criminal offence data, including maintaining an appropriate policy document.
Data Anonymization and Aggregated Information
FLEX GLOBAL TRADING may transform your Personal Data into statistical or aggregated formats to ensure you are no longer identifiable. We utilize this anonymous data for market research, analysis, and the creation of reports. These reports help us evaluate which product offerings generate the most interest among brokers and visitors to our Site.
We also employ technology to gather anonymous usage data. For example, we track the specific pages visited and the types of web browsers used by our audience. This process does not identify you personally but assists us in compiling helpful statistics about how our Site is navigated. Furthermore, we may monitor how frequently internal hyperlinks are accessed to better understand user preferences.
This anonymous information is vital for improving Site functionality. By identifying areas that attract significant attention, we can refine our communications and ensure our product and service offerings align with general visitor interests.
Third-Party Disclosures
We may share your Personal Data with third parties under specific circumstances, including:
- With our affiliated companies for the purposes detailed in this policy.
- With service providers who assist in our business operations, such as IT support or companies managing mailings, including our recruiting platform, Workday.
- With legal advisors and professional consultants.
- When required by law, for the administration of justice, to protect the integrity of our databases, or to mitigate legal liability.
- With government agencies or courts to comply with regulatory demands and legal orders.
- With third-party site managers who analyze data on our behalf, provided they adhere to these privacy protections.
Security and Protection Protocols
FLEX GLOBAL TRADING implements rigorous technical and physical measures to safeguard your Personal Data against loss, unauthorized access, or destruction. We utilize industry-standard SSL encryption for data transmissions and require our carefully selected service providers to maintain high protective standards.
Our security framework includes pseudonymization and encryption to ensure identity linkage is impossible without separate, secure information. We prioritize the ongoing resilience and integrity of our processing systems and maintain established protocols to restore data access quickly after any incident. We also conduct regular evaluations to test the efficiency of these security measures.
Data Retention Standards
We retain Personal Data only for the duration necessary to fulfill its original purpose or to comply with legal obligations. Our retention criteria consider several factors: we keep data for up to six months post-relationship to address queries, for up to ten years where required for potential legal claims (such as in Germany), and for longer periods if mandated by specific regulatory requirements.
For employment candidates, successful applicants will have their data transferred to a personnel file for employment purposes. For unsuccessful candidates, information is kept for six months unless explicit consent is given to retain it in our talent system for up to 24 months. You may withdraw this consent at any time, leading to the deletion of your personal information.
California Resident Rights
This section provides additional details for California residents under the CCPA and other state laws. Under the "Shine the Light" law, residents may request information once a year regarding how we share personal data with third parties for marketing purposes. Additionally, the "Eraser Law" allows residents under 18 to request the removal of content they have publicly posted on our platforms.
Under the CCPA, we collect various categories of information, including identifiers, commercial data, geolocation data, and sensitive information like social security numbers or biometric data. This data is sourced directly from you, our affiliates, and service providers. We do not sell or share your personal information as defined by California law.
Residents have the right to know what data we collect, the right to request deletion (subject to legal exceptions), and the right to correct inaccuracies. You also have the right to exercise these privacy choices without facing discrimination. Requests can be submitted to info@flexglobaltrading.com and are subject to identity verification.
Global Data Rights and Complaints
Depending on your location, you may have rights under other frameworks, such as the UK or EU GDPR. These include rights to access, rectification, erasure, and data portability, as well as the right to object to automated decision-making. If you have concerns, we encourage you to contact us directly. You also have the right to lodge formal complaints with authorities like the UK Information Commissioner’s Office.
External Links and Policy Updates
Our Site may link to external websites not managed by FLEX GLOBAL TRADING. We are not responsible for their privacy practices and encourage you to review their policies. We may update this Privacy Policy periodically; for significant changes, we will provide advance notice before they take effect.
Contact Us
To exercise your rights or if you have questions, please contact us at info@flexglobaltrading.com. Please include your contact details to allow us to process your request.