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GDPR PRIVACY POLICY

1. INTRODUCTION

Welcome to Headlands Tech's privacy notice. Headlands Tech respects your privacy and is committed to protecting your personal data. This privacy notice aims to give you information on how Headlands Tech collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children, that is, individuals under the age of 16 years.

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. In the event of a conflict between this notice and the other notices, this notice will prevail to the extent of the inconsistency.

CONTROLLER

This privacy notice is issued on behalf of Headlands Tech Holdings, LLC, Headlands Trading (UK) LLP, Headlands Technologies LLC, and Headlands Tech Global Markets, LLC and all of its affiliated companies (collectively, the "Headlands Tech Group") so when we mention the "Company", "Headlands Tech", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Headlands Tech group responsible for processing your data. Headlands Tech Holdings, LLC is the controller and responsible for this website.

We have appointed a Global Chief Compliance Officer 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 Global Chief Compliance Officer using the details set out below.

CONTACT DETAILS

Our full details are:

Headlands Tech Holdings, LLC, a limited liability company registered under the laws of the State of Delaware, USA with principal office at 155 North Wacker Drive, Suite 1900, Chicago, IL 60606, USA.

Headlands Trading (UK) LLP, a company organized under the laws of England and Wales with company registration number: OC386044 and registered office address at: Rex House, Suite 260, 4-12 Regent Street London, SW1Y 4PE, UK.

Contact details of the Global Chief Compliance Officer:

Email address: dataprotection@headlandstech.com

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

This version was last updated on the 24th of May 2018 and historic versions can be obtained by contacting us.

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.

THIRD-PARTY LINKS

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.

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. It does not include data where the identity has been removed (anonymous or pseudonymised 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, middle name or initial, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, office address, email address and telephone numbers.
  • Financial Data includes bank account and other payment details.
  • 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.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing information from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data, such as compilations of statistical or quantitative data for business purposes. 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we would treat the combined data as personal data which would 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.

3. 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, Financial and Technical Data by filling in forms, or by corresponding with us by post, phone, email or otherwise.
  • 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 and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Identity and Contact Data from other companies in our industry, including through their company websites, industry conferences and trade shows, and from financial industry and other publications (online and print).
    • Identity and Contact Data from other publicly availably sources, such as websites of governmental agencies and self-regulatory organizations (e.g., Companies House and the Electoral Register based inside the EU).

4. 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.

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 at dataprotection@headlandstech.com 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To manage our relationship with you, which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to update or confirm your information about you

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

To enable you to contact us, provide feedback or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Technical

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (for running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(c) Necessary to comply with a legal obligation

To deliver relevant website content

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Technical

Necessary for our legitimate interests

To use data analytics to improve our website

(a) Technical

(b) Usage

Necessary for our legitimate interests

COOKIES

A cookie is an element of data that a website can send to your browser, which is then stored on your system. A cookie is useful for having the browser remember specific information across several pages or between visits to a website. A cookie does not store personally identifiable information or any sensitive information. Also, our site does not read any information stored in cookies given to you from other websites, except in cases where the other website is a provider of information or functionality within our website and that cookie is necessary to make our website function correctly.

Our website makes use of cookies for the following purposes:

  • Website administration and personalization
  • Completing your request
  • Authentication purposes
  • Analysis of page and website information that does not identify specific individuals

You can set your browser to notify you when you receive a cookie, or to alert you when websites set or access cookies, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. In order to provide you with the best possible experience while visiting our website, please enable cookies within your browser. Many parts of our site do not function properly if you disable cookies. Logging off, however, will delete the cookies. Additionally, when a session times out, the cookie expires and is removed on close of browser or when new session is initiated.

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 at dataprotection@headlandstech.com.

To the extent we need to use your personal data for an unrelated purpose, we would notify you and 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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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 such 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.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Headlands Tech group. This will involve transferring your data outside the European Economic Area (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:

Please contact us at dataprotection@headlandstech.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. SECURITY OF PROCESSING

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 such a breach where we are legally required to do so.

8. DATA 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at dataprotection@headlandstech.com.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

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 accurately and lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we may hold about you corrected, though we may need to verify the accuracy of any 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 may be 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 or other legitimate grounds 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. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us at dataprotection@headlandstech.com.

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 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 data subject access 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.

10. GLOSSARY

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.

External Third Parties means

  • Service providers acting as processors based in the USA, United Kingdom and the European Union who provide IT and system services.
  • Service providers acting as processors or joint controllers based in the USA, United Kingdom, and European Union who provide financial market data and other financial trading-related services and systems with which we may be interconnected and used in the performance of a contract.
  • Service providers acting as processors or joint controllers based in the USA, United Kingdom, European Union, and Asia who provide an international exchange that may be interconnected and used in the performance of a contract.
  • Financial brokers, dealers and other counterparties acting as processors or joint controllers based in North America and Europe and Asia who provide or use financial trading services.
  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, accountants, insurers, marketing and other consultants based in the USA, United Kingdom, the European Union and Asia who provide legal, banking, accounting, insurance, marketing and other consultancy services.
  • Internal Revenue Service, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the USA and United Kingdom require reporting of processing activities in certain circumstances.

Internal Third Parties means other companies in the Headlands Tech Group acting as joint controllers or processors and who are based in the United Kingdom, France, Switzerland, Hong Kong and Singapore, and provide IT and system and administrative services.

Legitimate Interest means the interest of our business in conducting and managing our business. 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 at dataprotection@headlandstech.com.

Performance of a 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.