Please note that if you fail to provide us with personal data which we are obliged to collect by law, or under the terms of a contract that we have in place with you, we may not be able to provide our products and services to you, but will notify you at the time if this is the case.
PERSONAL DATA WE COLLECT ABOUT YOU
We will collect, use, store, and transfer different categories of personal data about you as follows:
Identity data. This includes your name and job title, and for certain CanDeal services accessed by you in the European Union (EU), will also include date of birth, nationality and national ID (such as your passport number).
Professional contact data. This is the data that allow us to contact you, and includes your e-mail address, postal address, and telephone number.
Technical data. This includes your internet protocol (IP) address (which helps to determine the location of the device you use to connect to our systems and to determine the number of devices simultaneously accessing the product), your username and password.
Professional profile data. This is data that you may provide to us about your job role, function and business focus.
CanDeal relationship data. This is data we obtain from our interactions with you, and includes details of any calls you have made to our support desk, visits made to you by our staff, marketing materials you have received, your e-mail communication with our staff, data about your preferred activities for marketing events or the CanDeal events you have attended, and your preferences in receiving marketing communications from us.
Product or subscription usage data. This is data we obtain about your usage of our products and services, including when and which products you have used, subscribed for or are enabled to access, and the content and functionality you have used in those products and services.
Publicly available information. This includes data we obtain from directories, website, public records or media sources.
Personal data collected from third parties. This is data we obtain from third parties, including for example information regarding your employment status and the results of any regulatory-screening processes, and could also include conference lists and financial services directories.
Referrals. As Tradeweb Markets LLC (“Tradeweb”) is CanDeal’s third-party technology provider, we obtain personal data from Tradeweb or Tradeweb clients. We also obtain personal data from Tradeweb as Tradeweb’s client-facing entity for Canadian regulatory purposes. Referrals also include data from other CanDeal clients.
Contests, surveys. This is data you provide us when you participate in our contests or surveys.
PURPOSES FOR WHICH WE WILL USE PERSONAL DATA
We process personal data for the following purposes:
Account setup and administration. We use personal data in order to set up your access to a product or service that you have subscribed for and to manage invoicing and payments.
Provision of service. We use the personal data we collect about you to provide you with our products and services, and to assist you in your use of these products and services. This includes providing you any necessary operational assistance, support and training, and alerting you to product changes or maintenance periods.
Product development and improvement. We will occasionally use the personal data that we collect about you to ask you to participate in surveys and questionnaires to improve, customize and enhance our products and services. In addition, we can use the data, combined in aggregate form with the personal data we have collected about other users of our financial products, for statistical purposes, or to plan and implement developments of, and enhancements to, our products and product range.
Compliance checks and regulatory recordkeeping. We use personal data to conduct compliance checks on our clients, and conduct system monitoring which CanDeal is required by law to carry out. We will also need to retain certain personal data for regulatory recordkeeping purposes.
SHARING PERSONAL DATA
We do not sell or otherwise disclose the personal data we collect about you, except as described below:
Tradeweb. As Tradeweb is our third-party technology services provider, Tradeweb has access to your personal data in order to provide operational and system administration services.
Your employer. We will provide your employer with reports containing the product usage data of its employees, for example performance reports.
Third party providers of content. We will share personal data with third-party content providers to which you have subscribed, where it is necessary for them to confirm that a user is entitled to access their content and to evaluate and manage how that content is used in our services.
Third Parties. We use other companies as data processors to process certain personal data on our behalf, including service providers who have access to your personal data in order to assist us in our administration of the services. For example, we use:
- customer relationship management software providers, such as Salesforce, in order to assist with the provision of our services and to contact you;
- financial communications services providers, such as Paragon Public Relations LLC, for public relations, marketing and strategic communications support.
Professional Advisers. Our professional advisers, including lawyers, auditors and insurers could have access to your personal data during the course of the performance of their professional services to us.
Disclosure for legal purposes. We will provide access to your personal data when legally required to do so, including, without limitation, to cooperate with regulatory and other government investigations or other legal proceedings.
Third party recipients of your personal data are only permitted to use it for the purposes of performing services on our behalf and in accordance with our instructions. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws.
TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
As Tradeweb is CanDeal’s third-party technology provider, we share personal data with Tradeweb which involves transferring it to different countries, including England and the United States.
If you are located in the EU, your personal data will be transferred on the basis set out in section 6 below.
SPECIFIC LEGAL DISCLOSURES
|Purpose for processing||Type of data||Lawful basis for processing|
|Account set up and administration||
||Performance of a contract with you
Necessary to comply with a legal obligation
|Provision of service||
||Performance of a contract with you
|Sales and marketing||
||Necessary for our legitimate interest (to develop our products or services and grow our business)
|Product development and improvement||
||Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products or services, to develop them, to grow our business and to inform our marketing strategy)
|Compliance checks and regulatory recordkeeping||
||Necessary to comply with a legal obligation|
Transfers of personal data outside of the EU
If you are located in the EU, the personal data that we collect from you will be transferred to and processed in Canada and in the United States by Tradeweb, and may also be held on servers by some of our service providers, for example Tradeweb and Salesforce, both in the United States. We ensure that any personal data which is transferred outside of the EU is appropriately safeguarded, including by using the appropriate legal mechanisms: the transfers of personal data are based on the European Commission’s model contracts for the transfer of the personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU; the transfer is to a country that has been designated as providing an adequate level of protection for personal data by the European Commission.
Your legal rights if based in the EU
You have certain rights afforded to you under European data protection laws in relation to our processing of our personal data if you are based in the EU:
- Access: the right to request access to your personal data and to find out how we use it and with whom it is shared.
- Correction: the right to request correction of the personal data that we hold about you or to have incomplete personal data completed.
- Erasure: the right to request that we erase the personal data that we hold about you in certain circumstances prescribed by EU law. Your request for erasure will be balanced against out legitimate requirements to process your personal data.
- Objection: the right to object to our processing of your personal data where we are relying on a legitimate interest and your specific situation means that you wish to object to processing on this ground as you feel that it impacts your fundamental rights and freedoms. You may also object to our processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms.
- Portability: the right to receive the personal data that we collect from you in a structured, commonly used and machine readable format, and the right to request that we transfer such personal data to another party.
- Withdraw consent: where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time.
You may at any time submit a personal data query, a request to exercise any of your above rights, or a complaint by contacting us by e-mail or post at: firstname.lastname@example.org
We maintain appropriate administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data you provide to us. We also limit access to your personal data to those employees, agents and contractors and other third parties who have a business need to access your data. They will only process your information in accordance with our instructions and are subject to a duty of confidentiality.
You may contact us to access the personal data you provide to us and to ask us to update, correct, or delete it from our databases, where it is legally permissible to do so. You may also request that we cease using your personal data for marketing purposes. If you do not wish to receive marketing e-mails or material materials from CanDeal about the products and services we provide, or if any of your contact details are incorrect, please let us know by calling us at 1-866-422-6332 or e-mailing us at email@example.com.
Last updated: 25 May 2018
It is important that the personal data that we hold about you is correct and up-to-date, so please notify us of any changes to your personal data during your relationship with us.