Glimpse Markets pools together and distributes aggregated financial and market data relating to the trading of financial instruments (the “Services”). Protecting data, privacy and personal information is very important to Glimpse Markets (“our”, “us” or “we”).
This policy (together with our Data Sharing and Service Agreement (the “Agreement”) and any other documents referred to in it), sets out the basis on which we process personal data (also referred to as “personal information” or “information”). This policy is addressed to our Clients’ and our prospective Clients’ employees, contractors, agents and any other authorised representatives (“you” or “your”). Please ensure you read this privacy policy carefully to understand the types of information we collect, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to personal data about you.
You will be asked to provide us with some basic information so that we can set you up with an account and so that we can manage this account. We will also ask you to provide some contact information so that we can reach out to you if that is necessary in relation to our Services. This information includes a user name and a password, your name, corporate email address and phone number.
We may approach you on social media and inquire whether you are interested in receiving our Services. We will use whatever information you have decided to publish on your, say, LinkedIn profile to do that.
We may also approach you via other online channels, such as email, Bloomberg IB chat, Symphony chat and other channels, if we believe our Services or any promotional materials about our Services may be of interest to you. We will use your phone number or email address to do that.
We will contact you if you fill in one of the web forms on our website. When we do that we will use the contact details you have decided to provide in the relevant form.
If your email or phone number has been given to us by another person, we will identify that person when first making contact with you.
When you visit our website certain technical information about the device you use to access our website that may identify you will be generated by cookies, web-beacons and other similar tracking technologies. You can learn more about this data collection in the ‘Cookies’ section below.
We will treat your information as confidential information and so shall our vendors do. We use various technological solutions providers in order to deliver our Services. They are prohibited from using your information for any purpose other than the delivery of their services to us. Nevertheless, depending on the type of vendor, they may have access to your information. These providers include our cloud storage providers, customer relationship management systems providers, email services providers, social media companies, analytics providers and others to assist us in promoting, delivering and improving our Services and our website.
In addition, we may also disclose your personal information to third parties in the following circumstances:
Purpose of disclosure:
If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets
Justification:
Legitimate interests (to allow the prospective investors to properly evaluate our business)
Purpose of disclosure:
If Glimpse Markets or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets
Justification:
Legitimate interests (to allow the prospective buyers to provide you the Services)
Purpose of disclosure:
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Glimpse Markets, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection
Justification:
Legal obligation
Purpose of disclosure:
Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies
Justification:
Legitimate interest (to assist with the prevention of fraud and to assess your risk profile)
Purpose of disclosure:
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime
Justification:
Legal obligation
No data transmission over the internet or website can be guaranteed to be completely secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
Sensitive information between your browser and our servers is transferred in encrypted form using secure socket layer (“SSL”) or equivalent cryptographic protocols using certificates issued by a trusted third party authority. We use hosted servers (such as Amazon Web Services) to deliver our Services. Our suppliers employ industry-leading standards in information security and contractually guarantee to keep your personal information secure.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share your password with anyone.
Your personal information will be stored electronically on computer systems located in the United Kingdom and managed by our vendors specified above. In certain circumstances your personal information may be accessed by staff, stored with or transferred by our vendors in, a destination outside the United Kingdom (UK) or the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the UK or the EEA.
Regardless of location or whether the person is an employee or contractor, we will impose data protection safeguards similar to those that we deploy inside the UK and the EEA. Where required by applicable law, we will transfer your personal information subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient. Please contact us if you would like further details of the specific safeguards applied to the export of your personal data.
We will hold the above information for as long as is necessary in order to conduct the processing detailed above, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 12 months. Some personal data may need to be retained for longer than this to ensure Glimpse Markets can comply with applicable laws and internal compliance procedures. Such personal data may be retained for up to 6 years.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the personal risk or harm from unauthorised use or disclosure, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under the General Data Protection Regulation (EU) 2016/679, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at paul.obrien@glimpsemarkets.com.
You have the right to:
to be informed; to access (such information); to rectification (of inaccurate information); to erasure; to restrict processing (in certain cases); to object to profiling;
to data portability (in certain cases); to complain to the Information Commissioner’s Office; to withdraw consent (if we have collected your personal information on this basis)
Detailed information on the full content of your rights (and any conditions that may apply) is provided by the United Kingdom’s Information Commissioner’s Office and is available on their website: https://ico.org.uk/your-data-matters/
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Glimpse Markets’ Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
While we will not sell your personal data (or any other data you provide us with) to third-parties, we reserve the right to share any data which has been anonymised. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to paul.obrien@glimpsemarkets.com.
For the purpose of the relevant data protection legislation, the controller is Glimpse Markets Ltd (company no. 12477371), with registered address at 63/66 Hatton Garden Fifth Floor Suite 23, London, England, EC1N 8LE.
The Site may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.
Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
