Bringing the corporate traders to the everyday retail trader
Corporate To Retail was founded to give an educational insight into the way that institutional traders think, trade & act. The aim of Corporate to Retail is to share with retail traders the proficiency & effectiveness of a corporate traders market approach.
Want to learn more about CTR?
Download our free brochure
Corporate to Retail hosts their master trading account that Richard Campbell manages on the Pelican App. The Pelican App allows you to auto-copy traders such as Corporate To Retail.
Corporate to retail aims to provide an institutional insight to retail traders. Our head of trading only knows this too well, after spending 30 years in the institutional sector. Corporate to retail provides free educational videos, market & position analysis via telegram and institutional market analysis reports.
How CTR Works:
Meet Richard Campbell
With almost 30 years experience in the FX markets, Richard has traded successfully with passion and discipline in almost every market condition there is.
Richard spent 20 years at Lloyds Bank and held various Senior roles including Head of FX Proprietary Desk and Head of 24 HR Trading. Richard spent 10 years as one of the top spot desk traders at Lloyd’s investment bank.
After leaving Lloyds, Richard ran a global team of Traders and a $25mio business. Richard has also been Head of FX Trading for Divisa UK and most recently Director of UK FX for Huge Group China.
How Richard's Strategy Works:
Richard Campbell uses the combination of diverse discretionary trading strategies as well as money management techniques that only experience and institutional level preparation can provide.
Richard adapts each strategy to existing and current market conditions since no strategy exists that will be profitable during all market conditions at all times, it's vital to be adaptive if you are to be successful.
Richard adapts himself to market conditions that ensure trading decisions are based on factors that move the market at that specific time. Adaptation to these environments is done through the analysis of shorter time frames using a combination of mathematical formulae that provide an indication of which direction the market may head to next and as always, mathematical algorithms and technical indicators can only be as good as the analyst or trader that is interpreting them.
Richard has had the privilege of working with some of the most exceptional traders, analysts, developers, and executives. Over the years, this has expanded greatly to allow him to discuss on a macro level what large conglomerate banking institutions and trade desks have in terms of ideas for an ever-changing market.
Richard makes certain that each trade is carefully monitored at all times as overall position and account risk management is overseen constantly by a manifold of custom developed programs and algorithmic tools that allows Richard to examine open position risk and historical performance metrics. Money management and risk management are the utmost indispensable elements of the trading methodologies Richard Campbell adapts.
Richard's Risk Management Framework:
AUM 5% Maximum DD per month on Notional
Maximum margin to equity is 15%.
Amount of AUM 10% Maximum DD per account on Notional Amount of AUM
Maximum equity per trade 1%.
Maximum risk per trade 0.5%
100% hard stops on each trade
Maximum 2.5% cumulative risk exposure of portfolio at any given time of Notional Amount of AUM
Non-Biased trading with maximum portfolio allocation in a Single Currency 50% of portfolio
THE PELICAN EXCHANGE -
Copy Trading Software
To copy the Master CTR account you can find the strategy on the Pelican Trading App. The Pelican App allows you to auto-copy traders. This means that all positions traded on the CTR account will be copied directly onto your trading account via the pelican exchange software.
If you’re interested in our partner's service, please register your interest below.
Spread betting and CFD trading are leveraged products and as such carry a high level of risk to your capital which can result in losses greater than your initial deposit. These products may not be suitable for all investors. CFDs are not suitable for pension building and income. Ensure you fully understand all risks involved and seek independent advice if necessary.
Disclaimer: For the avoidance of doubt Improve Your Future Ltd. (CTR) is not independently regulated by the FCA. CTR is a 'Signal Provider'; to Pelican Trading. Pelican Trading is a trading name of London & Eastern LLP. London & Eastern LLP is authorized and regulated by the Financial Conduct Authority in the UK, ref 534484. Registered address: 85 Great Portland Street, First Floor, London, W1 W7LT.
As we can accept your registration and make a legally enforceable agreement without further reference to you, you must read these terms and conditions to make sure that they contain all that you want and nothing that you are not happy with. If you are unsure on anything, please email us on firstname.lastname@example.org
1. These terms and conditions will apply to the purchase of the services and goods by you (the customer or you). We are Improve Your Future Ltd (Trading name - Corporate To Retail) a company registered in England and Wales under number 12107136 whose registered office is at Bryant House Bryant Road Strood Rochester Kent ME2 3EW with an email address of ‘email@example.com’ (The “supplier” “us” or “we”).
Corporate To Retail provides a number of Services, including trading tuition and trade ideas to trade currencies, stocks, commodities, currencies and worldwide indices on any platform of your choosing (collectively, “the Services”), for your individual educational usage only, subject to compliance with the terms and conditions set forth herein.
Corporate to retails hosts their service via London & Eastern LLP and affiliated brokerages.
By using the services offered by Improve Your Future Ltd, you are representing to Improve Your Future Ltd that you are at least 18 years old. You may not use IYF Trading Ltd’s website/services for any unlawful purpose.
CHANGES TO OUR WEBSITE
Our website is made available free of charge for non members. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change any part of our site without notice. We will not be liable to you for any reason if site becomes unavailable at any time or for any period.
REGISTRATION AND PRIVACY
In order to gain access to Improve Your Future Ltd’s service, you must provide us with your legal name, email address and phone number required on the registration page. If the information you provide is untrue, inaccurate, incomplete or outdated, or we have reasonable grounds to suspect it is, Improve Your Future Ltd has the right to suspend or terminate your purchase, and to prohibit your current or future use of the Service, or continue to charge you regardless of the fact that you are not receiving our product.
● You may not transfer or resell your use of or access to the Services to any third party;
● You are responsible for all activities that occur as a result of using our Services such as the placing of trades and resulting wins/losses;
● You are responsible for maintaining the confidentiality of our products features sent to you; and
● You agree to notify us; Improve Your Future Ltd if you become aware of any possible unauthorised use(s) of our service or any possible breach of security, including loss, theft, or unauthorised disclosure of your personal details.
Improve Your Future LTD (Trading name - Corporate To Retail ) is a trading partner of London & Eastern LLP, the regulated entity that oversees the provision of copy trading services. Corporate To Retail simply hosts its master account on the Pelican exchange app.
Corporate To Retail are in no way encouraging you to trade or follow our trades and we do not accept any responsibility for any losses you may suffer. We warn you again that trading has a risk of losses.
As this service is provided by London & Eastern LLP, upon interest you will be required to open an account with London & Eastern LLP. Spread betting and CFD trading are leveraged products and as such carry a high level of risk to your capital which can result in losses greater than your initial deposit. These products may not be suitable for all investors. CFDs are not suitable for pension building and income. Ensure you fully understand all risks involved and seek independent advice if necessary.
For the avoidance of doubt Improve Your Future Ltd. (CTR) is not independently regulated by the FCA. CTR is a 'Signal Provider'; to Pelican Trading. Pelican Trading is a trading name of London & Eastern LLP. London & Eastern LLP is authorized and regulated by the Financial Conduct Authority in the UK, ref 534484. Registered address: 85 Great Portland Street, First Floor, London, W1 W7LT. Spread betting and CFD trading are leveraged products and as such carry a high level of risk to your capital which can result in losses greater than your initial deposit. These products may not be suitable for all investors. CFDs are not suitable for pension building and income. Ensure you fully understand all risks involved and seek independent advice if necessary.
If a complaint is to be filed, the complaint must be sent to firstname.lastname@example.org . We aim to reply to all compliance within 5 working days.
When using Improve Your Future Ltd’s Services you may not republish, upload, post, transmit or distribute content available through the Services to online or offline bulletin boards, message boards, newsgroups, chat rooms, or in other any manner, without our prior permission. Modification of the content or use of the content for any purpose other than your own personal, non-commercial use is a violation of our copyright and other proprietary rights, and can subject you to legal liability.
You must abide by the following rules in connection with your use of our services:
● You agree not to violate any applicable local, state, national or international law in connection with your use of the Services. This includes, among other things, any securities law or regulation.
● You agree not to restrict or inhibit any other visitor from using the Service, including, without limitation, by means of “hacking” or defacing any portion of any of our web sites;
● You agree not to express or imply that any statements you make are endorsed by us, without our prior written consent;
● You agree not to modify, adapt, sublicense, translate, sell, reverse engineer, decompile or disassemble any portion of Improve Your Future Ltd’s website/s or Services;
● You agree not to “frame” or “mirror” any content available through Improve Your Future LTD’s website and the Services without our prior written authorisation;
● You agree not to use any robot, spider, site search/retrieval application, or other manual or automatic device or process to download, retrieve, index, “data mine,” or in any way reproduce or circumvent the navigational structure or presentation of the content available through Improve Your Future Ltd’s website/s or Service/s; or
● You agree not to harvest or collect information about users of the Services without their express consent.
LIMITATIONS ON USE
The Corporate To Retails website includes facts, views, opinions and recommendations of individuals and organisations deemed of interest. Improve Your Future Ltd and its Content licensors are not giving investment advice, tax advice, legal advice, or other professional advice. Improve Your Future Ltd believes its content and Services to be useful, but cannot guarantee accuracy or completeness.
DISCLAIMER OF WARRANTIES AND LIABILITY
Improve Your Future Ltd makes no representations that the materials provided are appropriate, available or useful in locations outside the U.K. Anyone who elects to use the website from other locations do so at their own risk and are responsible to comply with all local laws and rules that apply.
Some countries do not allow the disclaimer of implied warranties, so the above disclaimers may not apply to you in all instances. None of Improve Your Future’s staff, consultants, contractors, or third-party content providers shall be liable for damages arising out of or in connection with the use of the website. UNDER NO CIRCUMSTANCES SHALL IMPROVE YOUR FUTURE LTD OR ANY PARTY INVOLVED IN CREATING, PRODUCING OR DISTRIBUTING THE WEBSITE BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES THAT RESULT FROM THE USE OF OR INABILITY TO USE THE WEBSITE, TRADE IDEAS OR OTHER EDUCATIONAL MATERIAL including, but not limited to, damages due to: loss of data, income or profit; loss of or damage to property; claims of third parties; reliance by a user on information obtained from Improve Your Future Ltd’s website or any linked website; errors, omissions or interruptions; deletion of files or email; defects, viruses, delays in operation or transmission or any failure of performance; communications failure; and theft, destruction, or unauthorised access to Improve Your Future’s records, programs or Services. You agree that this paragraph shall apply to all content and Services available through the web or via phone. Some states do not allow the exclusion or limitation of consequential or incidental damages, so the above limitations may not apply to you in all instances.
You agree to indemnify, defend and hold us, our officers, directors, workers, employees, agents and representatives harmless from and against any and all claims, damages, losses, costs (including reasonable lawyers’ fees), or other expenses that arise directly or indirectly out of or from (a) your violation of the TOU; (b) your use of the Site; or (c) your violation of the rights of any third party.
To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied. We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
● use of, or inability to use, our website/s; or
● use of or reliance on any content displayed on our site.
If you are a business user, please note that in particular, we will not be liable for:
● loss of profits, sales, business, or revenue;
● business interruption;
● loss of anticipated savings;
● loss of business opportunity, goodwill or reputation; or
● any indirect or consequential loss or damage.
If you are a consumer user, please note that we only provide our site for domestic and private use. You agree not to use our website/s or Services for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.
We assume no responsibility for the content of websites linked on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.
Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any goods by use to you, which will be set out in our Terms and conditions of supply.
We do not guarantee that our site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform in order to access our site. You should use your own virus
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
LINKING TO OUR SITE
You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link to our site in any website that is not owned by you. Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice.
MISCELLANEOUS LEGAL TERMS
This Agreement is personal to you, and you may not assign your rights or obligations to anyone. If any provision in this Agreement is invalid or unenforceable under applicable law, the remaining provisions will continue in full force and effect. This Agreement, your rights and obligations, and all actions contemplated by this Agreement shall be governed by the laws of England and Wales, without regard to its conflict of laws rules or choice of law provisions, as if the Agreement was a contract wholly entered into and wholly performed within England and Wales. You and Improve Your Future Ltd hereby expressly consent to the exclusive jurisdiction of courts in England and Wales. For all disputes arising out of this Agreement if Improve Your Future Ltd prevails in such dispute, it shall be entitled to recover, in addition to such damages as may be found by the courts, its reasonable lawyers’ fees and costs, including those related to or arising out of any injunctive proceedings.
If you have any questions about these Terms & Conditions, the practices of this site, or your dealings with this site, please contact us at: email@example.com
Terms & Conditions
This website & further information on the service contains Affiliate links. The affiliate links are in the form of Banner Ads, and Text Links. We receive one simple commission on each referral via the hypertext link to our vendor partner.
Clicks are tracked by means of a code that is contained in our Affiliate links. These Affiliate links help us to cover the costs of hosting this website & service. We only promote products that we use and strongly endorse ourselves. Our affiliate relation has no effect on the price you pay for the affiliated product. Registering for an associated service & actions thereafter is completely the choice of the consumer.
The use of our information, products and services should be based on your own due diligence and you agree that https://www.corporatetoretail.com/ and the advertisers / sponsors of this website are not liable for any success or failure of your business that is directly or indirectly related to the purchase and use of our information, products and services reviewed or advertised on this website.
Welcome to the Improve Your Future Limited’s privacy notice.
Improve Your Future Limited’s respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Improve Your Future Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, blog or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Improve Your Future Limited is the controller and responsible for your personal data (collectively referred to as “Improve Your Future Limited”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Improve Your Future Limited
Name or title of DPO: Jake Lee
Email address: firstname.lastname@example.org
Postal address: Bryant House Bryant Road Strood Rochester Kent ME2 3EW
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
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 may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you begin registering for a partners service you consent to your name, email address and phone number being shared with our partners.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes [first name, , last name, username or similar identifier, title, date of birth and gender].
Contact Data includes [billing address, delivery address, email address and telephone numbers].
Financial Data includes [bank account and payment card details].
Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
Usage Data includes [information about how you use our website, products and services].
Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by 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;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
Technical Data from the following parties:
advertising networks based [inside OR outside] the EU; and
search information providers based [inside OR outside] the EU].
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based [inside OR outside] the EU].
Identity and Contact Data from data brokers or aggregators based [inside OR outside] the EU].
Identity and Contact Data from publicly available sources.
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 or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us on email@example.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which 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 where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes 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 wish to get an explanation as to how 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.
TC “5. Disclosures of your personal data” \l 1Disclosures of your personal data
We may have to share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TC “6. International transfers” \l 1International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
[IF TRANSFERS OUT OF EEA OCCUR:] [We share your personal data within the [COMPANY] Group. This will involve transferring your data outside the European Economic Area (EEA).]
[Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.]
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
TC “7. Data security” \l 1Data 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.
TC “8. Data retention” \l 1Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
TC “9. Your legal rights” \l 1Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data and to access the same as set out in the Glossary. If you wish to exercise any of these rights then please do contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
TC “10. Glossary” \l 1Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You agree that we may contact you for promotional purposes or to fulfil our contractual obligations via Whats App and any other online communication methods after receiving your contact details.