Last Modified: May 25, 2018
This Privacy Notice explains how Thalēs Trading Solutions LLC and Thalēs Capital Partners LLC (“Thalēs” or “we”) collect, use, and disclose personal data online and offline in connection with the services we provide to our clients (“Services”), including the regulatory obligations we have in providing these Services. We refer to the individuals whose Personal Data (as defined below) we process as “you” in this Notice.
“Personal Data” is information that identifies an individual or relates to an identifiable individual. Outside of the information we collect in order to communicate with you as we provide our Services, our regulatory obligations require that we collect Personal Data as it is represented on your government issued ID’s (such as a Driver’s License or Passport). Examples of Personal Data we collect include:
- Account details and related contact information
- Postal address
- Telephone, fax, email address, and other identifying addresses for electronic communications
- Date of birth
- Photographic or video images
- Telephonic or electronic recordings
- Details represented on your government issued IDs
We need to collect and process Personal Data in order to provide the requested Services or because we are legally required to do so. If we do not receive the information that we request, we may not be able to provide the requested Services.
Collection of Personal Data
We collect Personal Data directly from you through the communication required for us to provide our Services. When we request this information from you, we also provide you notice of our privacy and other data protection policies. Given your notice of our policies, we understand your provision of any requested information as a consent to our use of this information as we describe in our policies. You may revoke this consent at any time by emailing firstname.lastname@example.org and we will respond to your request within a reasonable time. We will retain the information that you provide us only as it is required by our regulatory obligations. If required to meet our regulatory obligations, we may also receive Personal Data from other sources, such as public databases, employers, the entity we provide our Services to, and from other third parties.
We take the security of your Personal Data seriously. Unless required to comply with regulatory or other legal obligations, only our employees have access to the information you provide to us. Additionally, we have implemented measures designed to secure this information from accidental loss and from unauthorized access, use, alteration, and disclosure. In addition to our strong password and authentication policies, we have implemented multiple layers of security to our systems, including up-to-date anti-virus and anti-malware software. All information you provide to us is stored on our secure servers behind firewalls.
We have also implemented a Data Breach Plan for recognizing and responding to data breaches. In the event of a data breach, we will initiate the notification procedures required by the Data Breach Plan and notify the appropriate authorities within seventy-two hours after discovery.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk, and we are not responsible for circumvention of any privacy settings or security measures related to our Services. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by emailing email@example.com.
We recognize that there are additional risks that countries, such as those in the EU, associate with transferring Personal Data to the United States. As a U.S.-based company, we work hard to mitigate these risks through not only our security measures but also by only using trusted third-party services to help transfer, process, and store your information as well as communicate with you. These services include:
- Global Relay, a Canadian-based company operating under Canadian law whose adequate privacy protections are recognized under Article 45 of
- Regulation (EU) 2016/679.
- Google, which is certified as compliant under both the EU-U.S. and Swiss-U.S. Privacy Shield Framework. You may view their certification here.
- Mailchimp, which is certified as compliant under both the EU-U.S. and Swiss-U.S. Privacy Shield Framework. You may view their certification here.
- We are, however, ultimately not responsible for the privacy or other practices of any third parties.
Use of Personal Data. We use your Personal Data solely to provide you the Services you’ve requested and to meet our regulatory obligations in providing our Services to you. As part of these regulatory obligations, we collect this information in order to meet our legal and regulatory obligations related to the prevention of money laundering and terrorist financing.
Other Uses or Disclosures
We may use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law including treaties or agreements with or between foreign or domestic governments, which may include laws outside the country you are located in, to respond to requests from public and government authorities, which may include authorities outside your country to cooperate with law enforcement, governmental, regulatory, securities exchange, or other similar agencies or authorities including tax authorities to which we or our affiliates are subject or submit, in each case of any country worldwide, or for other legal reasons, who may transfer the Personal Data to equivalent agencies or authorities in other countries; (b) to central banks, regulators, trade data repositories, or approved reporting mechanisms which may be outside your country; (c) to courts, litigation counterparties and others, pursuant to subpoena or other court order or process or otherwise as reasonably necessary, including in the context of litigation, arbitration and similar proceedings to enforce our terms and conditions, and as reasonably necessary to prepare for or conduct any litigation arbitration and/or similar proceedings; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
In addition, we may use, disclose or transfer Personal Data to a third party (i) in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings) and/or (ii) to third parties, as requested by clients or their representatives.
Choices and Access
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt-out from receiving electronic communications from us by emailing firstname.lastname@example.org. We will try to comply with your request(s) as soon as reasonably practicable for us. We may still send you important administrative, Service, or transaction-related messages.
If you would like to request to review, correct, update, suppress, restrict, or delete Personal Data that you have previously provided to us, you may contact us at email@example.com. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We do not collect sensitive Personal Data in connection with our Services. Please do not send us any Personal Data such as information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, biometric or genetic characteristics, criminal background or trade union membership) (“Special Data”).
Updates to this Privacy Notice
We may change this Privacy Notice from time to time. When we do, we will notify you directly.
Individuals in the EU and greater European Economic Area, please note that you may file a complaint with a supervisory authority in your relevant country or region regarding this notice and our data protection policies and practices.
We are responsible for the collection, use, and disclosure of your Personal Data under this Privacy Notice. To ask questions or comment about this Privacy Notice and our practices, please contact us at firstname.lastname@example.org.
Thalēs Trading Solutions LLC
Attention: Privacy Inquiries
540 Madison Avenue, 4th Floor
New York, NY 10022