Elwood Technologies (“Elwood”) shall mean Elwood Holdings Limited and its direct and indirect subsidiaries from time to time (each a “Company”, and together the “Elwood Group”).
Your privacy is really important, which is why protecting your data is a top priority for Elwood. Elwood collects certain information from users of its systems and services via its website at https://elwood.io/ (“Website”). This includes the data obtained through interaction with the Website and any direct communications with our office and support teams (“Website Data”).
This privacy notice also applies if you are a prospective employee of our organisation (“Candidate”). An Elwood Company may act as a data controller in respect of personal data processed by us in a recruitment process (“Candidate Data”). Employee data is governed by a separate privacy policy.
This privacy notice provides information on how Elwood collects and processes the Website Data and Candidate Data with regards to the rights that individuals have under the data protection legislation within which Elwood operates.
The words “our”, “us”, “we” and “Elwood” shall refer to the Elwood Group (as defined above).
Website Data
The following section details the information Elwood collects via the Websites.
What we collect
Elwood may collect the following Website Data:
- questions, queries, feedback or responses to surveys that you provide, including email addresses if an email is sent to an address listed on the Website;
- information sent to us via email;
- information entered when using search facilities on the Website;
- IP addresses from which an individual accesses the Website, and details of which version of web browser and operating system were used;
- click stream data – this includes information on how individuals use the Website, using cookies and page tagging techniques;
- the address of the website from which individuals are directed to our Website;
- information that may be submitted to us anonymously where users of our Website are not signed into our Website.
Elwood uses and processes this Website Data to enable it to carry out its business functions, including but not limited to the following purposes:
- responding to any feedback sent to us;
- operating and enhancing the Website;
- determining the purposes for which such data was sent to us;
- meeting any legal or regulatory requirements;
- aggregating anonymised data to run data analytics.
Platform UserData
The following section details the information Elwood collects from Website users who go on to use either of (i) the Order and Execution Management System (OEMS) which facilitates the execution and monitoring of trading across exchanges and liquidity providers and/or; (ii) the Portfolio Management System (PMS) which reflects a customer’s positions, portfolios and allocations across the relevant exchanges, each a “Platform”. The data collected from users who use the Platform shall be called “Platform Data” for the purposes of this Privacy Notice.
What we collect
Elwood may collect the following Platform Data:
- username;
- email address;
- other contact details if applicable.
Elwood uses and processes this Platform Data to enable users to access the Platform in a secure and monitored environment.
Candidate Data
The following section details the information Elwood collects from prospective candidates.
What we collect
Elwood may collect and process the following Candidate Data:
- information about you that you give to us (i.e.name, email address, telephone number etc.) or by communicating with us, whether face-to-face, by phone, e-mail or otherwise through the recruitment process;
- your full name, date of birth, nationality, education and qualification details, marital status, home address and home telephone number, mobile telephone number, next of kin, emergency contact and dependent details (including contact information, date of birth and nationality), bank account details for the transfer of your salary and other benefits, tax details and your date of hire;
- information obtained from other sources including education and qualification details, confirmation of address, credit and criminal record checks for background screening purposes.
Elwood uses and processes this data
● to meet and perform our legal obligations as an employer;
● contact you about your prospective employment;
How we collect your data
You directly provide Elwood with most of the data we collect. We collect data and process data when you:
● register online or complete an online contact request form;
● voluntarily complete a customer survey or provide feedback on any of our message boards;
● use or view our Website via your browser’s cookies; make an application for a position at Elwood
How we use your data
Elwood collects your data so that we can:
● process your request and manage your account and account preferences;
● contact you with any details related to your specific query;
● improve the Website from time to time;
● aggregating anonymised data for data analytics;
● process prospective employment applications
Elwood may also need to share Website Data and Candidate Data with third parties outside of the Elwood Group for the following purposes:
● if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
● if we are acquired by a third party, in which case personal data held by us may be disclosed to that third party buyer; and
● to third party agents and contractors for the purposes of providing services to us, including payroll, benefits, HR, insurance, IT, background screening and communications providers, law firms, benefit and insurance brokers, accountants and auditors.
In addition, we may be required by law or regulation to share personal data with third parties or with regulatory and/or government authorities. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and, 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, establish, exercise or defend our legal rights, provided, in each case, that the data is governed by the same standards of protection as provided by Elwood.
How we store your data
Elwood securely stores all your data on our information systems. Data is only stored for the period necessary to meet our data processing obligations and will be immediately removed from our systems when no longer required (subject to the organisation’s legal and regulatory obligations).
Marketing
Elwood would like to send you marketing information that we think you might like. You may always opt out of receiving marketing materials at a later date by following the “Unsubscribe” links in any marketing message sent to you or contact legal@elwood.io.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour detail. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
How we use cookies
Elwood uses cookies in various ways to improve your experience on our Website, including keeping you signed in, and to understand how you use our website.
A number of cookie types are used on the website as follows:
Functional. Used so that we can recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Usage. Used to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
How to manage cookies
You can set your browser not to accept cookies and remove any unwanted cookies from your browser (the relevant product details should be consulted for this purpose). However, in a few cases, some of our website features may not function as a result.
Your Data Protection Rights
Elwood would like to make sure you are fully aware of all your data protection rights. Every Website user is entitled to the following:
The right to access. You have the right to request Elwood for copies of any personal data that we may have related to your interaction with our website. We may charge you a small fee for this service.
The right to rectification. You have the right to request that Elwood correct any information you believe is inaccurate. You also have the right to request Elwood complete the information you believe is incomplete.
The right to erasure. You have the right to request that Elwood erase your personal data, under certain conditions.
The right to restrict processing. You have the right to request that Elwood restrict the processing of your personal data, under certain conditions.
The right to object to processing. You have the right to object to Elwood’s processing of your personal data, under certain conditions.
The right to data portability. You have the right to request that Elwood transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month from Elwood’s receipt of your request to respond to you.
With respect to personal data, you can exercise your rights to obtain information, withdraw your consent to processing, receive personal data in a structured format, rectify your personal data if inaccurate or incomplete, erasure, restrict the processes of your personal data by contacting us using the details set out in the “Contacting us” section below.
Retention of information
The length of time Elwood holds your data for will vary. The retention period will be determined by the following criteria:
● whether the data amounts to personal data;
● the purpose for which we are using your personal data – 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 on file.
Privacy Policies of other websites
Our Website may contain links to other websites. This privacy notice applies solely to our Website and not to any third party’s website. In the event you visit a third party’s website or utilise their services, you should review and place reliance on that third party’s privacy notice.
Accuracy of information
We have taken reasonable care to ensure that the information on our site is accurate, current, complete, fit for its intended purpose and compliant with applicable law and regulation as at the date of issue. However, errors or omissions may occur due to circumstances beyond our control and no warranty is given, or representation made, regarding the accuracy, validity or completeness of the information on our site and no liability is accepted by us for the accuracy or completeness of such information.
Transfer of your data outside the European Economic Area
The personal data that we collect from you may be transferred to, and stored at, a destination outside the EuropeanEconomic Area (EEA). It may also be processed by individuals operating outside of the EEA who work for our affiliates or for one of our suppliers.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:
● The country that we send the data to might be approved by the European Commission as offering a sufficient level of protection;
● The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data.
You can obtain more details about the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.
Changes to our Privacy Notice
We may change this privacy notice at anytime. In that case, the date at the bottom of the Website page will also change. Any changes to this privacy notice will apply to any individuals using Elwood’s website or online services, or applying for prospective employment, and their data, immediately.
Consent
By using our Website, you (i) consent to the processing of your personal data in accordance with this privacy notice, (ii) warrant that all data provided by you is true and accurate, and (iii) agree that unless you have set your device’s browser to reject them, we can place the types of cookies set out above on your device, and use the data derived from such cookies in accordance with this privacy notice.
Candidates here by consent to the processing of your personal data in accordance with this privacy notice.
Contacting Us
If you have any questions about Elwood’s privacy notice, the data we hold on you, would like to exercise one of your data protection rights, or if you would like further information on the collection, use, disclosure, transfer or processing of your personal data, please do not hesitate to contact us at our email: legal@elwood.io.
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Elwood has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office. Details are available at https://ico.org.uk/global/contact-us/.
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