PRIVACY POLICY

Protecting your rights and General Data Protection Regulation (GDPR)

This privacy policy notice is served by:
Twenty Trade SA under the website https://www.twentytrade.com

The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website. If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us. Policy key definitions:"I", "our", "us", or "we" refer to the business, Twenty Trade SA  and "you", "the user" refer to the person(s) using this website.

GDPR refers to the General Data Protection Act.
PECR means Privacy & Electronic Communications Regulation.
ICO means Information Commissioner's Office.
Cookies mean small files stored on a users computer or device.

Key principles of GDPR:
Our privacy policy embodies the following key principles;
(a) Lawfulness, fairness and transparency
(b) Purpose limitation
(c) Data minimisation
(d) Accuracy
(e) Storage limitation
(f) Integrity and confidence
(g) Accountability.

Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

Data retention period
We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.

Sharing your information:
We do not share your information with third parties. If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here including the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; the right to object; and the right not to be subject to automated decision-making including profiling. You also have the right to complain to the ICO if you feel there is a problem with the way we are handling your data. We handle subject access requests in accordance with the GDPR.  Our methods meet the GDPR compliance requirement.

Fair & Transparent Privacy Explained
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users. Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages.

Where used, such marketing messages may record a range of data such as; times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.Any email marketing messages we send are in accordance with the GDPR and the PECR.

We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, or you can contact Twenty Trade SA  and we will remove you from any lists.


Resources & further information

Overview of the GDPR - General Data Protection Regulation
Data Protection Act 2018
Privacy and Electronic Communications Regulations 2003
The Guide to the PECR 2003



Privacy Notice Policy Base: v.4.1 Dec 2019

LOCATIONS

Strategic representation for finance and major commodoties markets access

Geneva

Rue Arnold, Winkelreid 6, Geneva 1201, Switzerland

Tel: +41 22 301 300

Istanbul

Flora Residence No 1, Floor 28, D.No 2803, 34750 Atasehir, İstanbul, Turkey

Tel:  +90 212 328 12 15

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