Website Privacy Statement
Zodia Markets respects your privacy and we are committed to keeping your personal data and other data confidential and secure.
1. Important information and who we are
This Website Privacy Statement tells you the types of information we collect about you when you visit our website, use our products and services, interact with us offline, or which we otherwise obtain directly from you or from another party. It also outlines how we use that information and how we may share it.
This Website Privacy Statement is issued on behalf of Zodia Markets Holdings Limited and the members of the Zodia Markets Group, including Zodia Markets Holdings Limited, Zodia Markets (UK) Limited and Zodia Markets (Ireland) Limited, “Zodia Markets”, “we”, “us”, or “our”.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
When you use this Website, our products or services, or otherwise interact with us, we collect the following personal data about you:
a) Direct interactions. You may give us your personal data by filling in forms or corresponding with us by social media, post, phone, email or otherwise. This includes personal data you provide when you:
· apply for our products or services;
· create an account on our Website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· apply for an advertised or speculative role with us;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
This information may include your name, address, email address, ID documentation (e.g. passport or driver’s license), username or similar identifier, log-in credentials of authorised users of our services, job title, relationship with our corporate customer, information inputting into our platform as determined or instructed by our corporate customer, call recordings, marketing preferences and other identity, contact or profile details. Given the free text nature of some of our forms, completing them may also involve you, at your option, providing us with additional personal data.
We collect personal data through our Website in connection with applications for employment which will include your name, date of birth, email address, phone number, address, other contact details and employment history. This data will be used to determine your suitability for a position within Zodia Markets and the wider Standard Chartered Bank Group and, if applicable, your terms of employment or engagement. Your Information may also be used to monitor our recruitment initiatives and equal opportunities policies.
c) Other parties or publicly available sources. We may receive personal data about you from certain third parties and public sources including:
· other companies in the Zodia Group, Standard Chartered Group and other affiliates;
· your employer, our corporate customers or suppliers with which you have a relationship or are an authorised representative/user;
· recruitment agencies;
· social media sites (such as LinkedIn); and
· other publicly available databased such as Companies House.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. However, where we do rely on consent (such as in relation to direct marketing), you have the right to withdraw such consent at any time by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Purposes for which we will use your personal data
We will use your personal data for the purposes of providing and operating the product or service you request or responding to your communications and request and for other related purposes that may include:
- to register new customers;
- to manage payments, fees and charges / collect and recover money owed to us;
- to manage our relationship with you;
- updating and enhancing our records about you and understanding your financial needs;
- crime or fraud detection, prevention and prosecution;
- complying with laws or regulations;
- planning, conducting and monitoring Zodia Markets’ business including research and statistical analysis with the aim of improving our Website, products and/or services, based on our legitimate interest in doing so;
- in line with voluntary codes and/or in compliance with internal policies (including that of other Standard Chartered Group entities), contractual obligations (including between us and our affiliates), good practice standards and other requirements where it is in our legitimate interest to do so;
- handling queries and complaints;
- to deliver relevant website content and advertisement to you and measure and understand the effectiveness of the advertising we serve to you; and
- to make suggestions and recommendation to you about goods or services that may be of interest to you
We will not use take any automated decisions toward you based on your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your personal data to form a view on what products, services or other offerings we think you may want or need, or what may be of interest to you. You may receive marketing communication from us if you have requested information from us, have consented to marketing or have purchased goods or services from us and you have not opted out of receiving that marketing or where we are otherwise legally permitted to send you marketing.
Change of purpose
We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to you the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosing your personal data
When using your personal data, depending on the type of personal data and the purposes of processing, we may disclose it to:
- other companies within Zodia Markets and the wider Standard Chartered Bank Group anywhere in the world (including affiliates) in order to provide services to you, for business management or administration or to fulfil our legal or regulatory obligations;
- third party service providers, subcontractors, agents and other organisations who provide services to us in connection with the operation of our business or to you on our behalf such as IT and cloud hosting providers, HR and administrative services, financial and accounting, recruitment agencies, onboarding / ID verification;
- professional advisers including lawyers, bankers, auditors, accountants and insurers;
- in relation to job applicants, educational institutions, previous employers, credit reference agencies and recruiters;
- anyone authorised by you, as specified by you or in any contract with you;
- third parties where we choose to sell, transfer or merge parts of our business or our assets;
- our customers in connection with the products and services we provide to them;
- regulators who regulate how we operate, including the Financial Conduct Authority and the Information Commissioner’s Office; and
- any person or organisation to whom disclosure is required or permitted under applicable laws and regulations.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where third party service providers act as processors on our behalf, we do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.
5. International transfers
We may transfer your personal data outside of the UK / EEA where we have affiliates or service providers based in countries elsewhere in the world.
Where we transfer your personal data outside of the UK / EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
· We transfer your personal data to countries that have been deemed to provide an adequate level of protection by the UK Secretary of State or the European Commission.
· We implement certain standard contractual clauses with the recipients of your personal data to safeguard transfers to countries outside of the UK / EEA.
Please contact us if you would like further information about the specific mechanism used by use when transferring your personal data out of the UK / EEA.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, we reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.
7. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.
Generally, we will only retain personal data related to a particular client contract for 7 years following the termination or expiry of that relationship. Personal data relating to unsuccessful job applicants is usually retained for 6 months.
In some circumstances you can ask us to delete your personal data (see your rights below).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your rights
You have other rights regarding the processing of your personal data. Under certain circumstances, you have the right: to make a request to access, correct, erase or restrict the use of, or to object to the way in which we process, the personal data we hold about you, or to make a request to withdraw any consent previously given. If you would like to exercise any of these rights, you can contact our Data Protection Officer (details below).
9. Contacting us
If you have questions, concerns or complaints about our Website Privacy Statement or our processing of your personal data more generally, please contact our Data Protection Manager at:
The Data Protection Manager, Zodia Markets (UK) Limited, 1 Basinghall Avenue, London, EC2V 5DD
Email: [email protected]
You also have the right to complain to the applicable data protection authority. In data protection authority in the UK is the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint).
10. Changes to our Website Privacy Statement and your duty to inform us of changes
We update our Website Privacy Statement from time to time and you are advised to check this Website regularly to make sure you are familiar with the most recent version.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Website Privacy Statement was last updated in February 2023.