Privacy Policy

Background
PBA Brokerage understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it, and use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

It is important that you read this Privacy Policy 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 Policy supplements the other notices, and is not intended to override them.

Our Site is not intended for children and we do not knowingly collect data relating to children.

Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. INFORMATION ABOUT US
www.pbabrokerage.com (referred to as “Our Site” in this Privacy Policy), is owned and operated by PBA Trading Limited, a private limited company registered in England under 06779181 of Basepoint, Riverside Court, Beaufort Park Way, Chepstow, Monmouthshire, NP16 5UH, United Kingdom.

PBA Trading Limited (referred to as “we”, “us” or “our” in this Privacy Policy) is the controller and is responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in section 11 below.

2. SCOPE – WHAT DOES THIS POLICY COVER?
This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

WHAT DATA DO WE COLLECT AND HOW?
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).

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.

3.1 Data you provide to us.
There are different ways in which you provide information to us. These include:

Submitting a contact form
When you submit a contact form you will provide your name and email address as well as any other details you include in the ‘message’ box.

Signing up to our newsletter
You can register for our newsletter on Our Site. You can do this on our Services, Terms & Conditions or Contact page. You can also sign up through the newsletter sign up box found in the footer of our website. To subscribe to our newsletter, you need to provide your email address.

3.2 Data We Collect Automatically
Some data will be collected automatically by Our Site through cookies – this data is anonymized.

You can control cookies through your browser settings and other tools. For further details on information collected automatically by our cookies, please see our Cookie Policy.

4. HOW DO WE USE YOUR DATA?
We will only use your personal data when the law allows us to.  Please refer to the Glossary for details about the “lawful basis for processing” principles, which set out what is allowed under the GDPR.

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.

We have set out below a description of all the ways we plan to use your personal data. We have also identified what our legitimate interests are where appropriate.

4.1 Our Services
We use the data that we have about you to provide and personalise, our Services, so that they can be more relevant and useful to you. This includes:

Enquiries.
Data provided to us through the contact form on our website is used by our personnel to respond to your enquiry. Should you choose to enter into a contract with us following your enquiry, contact information, and in particular your email address, is used to send information regarding your contract. Data for all contracts is retained for customer service, analytics, marketing, and accounting purposes.

4.2 Marketing and Advertising
With your permission and where permitted by law, We may also use your data for marketing purposes which includes contacting you by email and/or telephone and/or post, with information, news and offers on Our products and services, depending on what you have agreed to.

We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and all other applicable laws.

You may change your communication preferences at any time by unsubscribing within any of our marketing emails. Please be aware that you cannot opt-out of receiving service messages from us, including transactional communications as well as security and legal notices, although you can in some circumstances ask for your personal data to be deleted.  Please refer to section 9.3 below for details about your right of erasure.

4.3 Important Updates
From time to time we may need to send you important updates or notices such as communications about changes to this Privacy Policy or our Terms and Conditions.

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 would like 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.  See section 5 below for more details.

5. DO WE SHARE YOUR DATA?

5.1 We use third parties to help us provide our services to you and in some cases, these third parties may require access to some or all of your data, as reasonably necessary to perform these tasks on our behalf. We share relevant data with:

Our third party marketing platform so that we can analyse your preferences and send you marketing and important update emails;

Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

5.2 We may 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 Policy.

5.3 In certain circumstances We may be legally required to share data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

5.4 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.

6. HOW YOUR DATA IS KEPT SECURE
Data security is of great importance to Us, and 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.

Steps We take to secure and protect your data include:

6.1 HTTPS encryption is used throughout the website to help prevent the interception of your data.

6.2 In addition, data may be stored with our third-party marketing provider. While we do not control how this third party protects your data, we take precautions to ensure that all data is stored and used in accordance with applicable regulations and that only trusted services are used.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to Us via the internet.

7. HOW CAN YOU CONTROL YOUR DATA?
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.

In some circumstances you can ask us to delete your data: see section 9 below for further information.

In some circumstances we may 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
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

8.1 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.

8.2 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.

8.3 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.

8.4 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.

8.5 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.

8.6 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.

8.7 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.

If you wish to exercise any of the rights set out above, please contact us.

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.

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.

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.

9. CONTACTING US
If you have any questions or complaints about Our Site or this Privacy Policy, please contact Us by email at andrew@pbabrokerage.com, by telephone on +44 (0)7801 735697, or by post at: PBA Trading Limited, Basepoint Business Centre, Riverside Court, Beaufort Park Way, Monmouthshire, NP16 5UH, United Kingdom.

Please note that 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 using the contact details set out above.

10. CHANGES TO OUR PRIVACY POLICY
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This version was last updated on 24th May 2018 and historic versions can be obtained by contacting us.

GLOSSARY

“Cookie” Means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in our Cookie Policy;
“GDPR” The General Data Protection Regulation (EU) 2016/679;
“Lawful Basis for Processing” We will only collect and process personal data about you where we have a lawful basis. Our lawful bases include:

Consent
Where you have given us consent to process your personal data for a specific process. For example, if you have opted in to our marketing emails. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time.

Contract
Where processing is necessary for the performance of a contract with you.

Legitimate Interests
Where processing is necessary for the purpose of our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests. Where we rely on legitimate interests to  process your personal data, you have the right to object.