Last update: 18 July 2022
SIGMA FINANCIAL LTD understands that your privacy is important to you and that you care about how your personal data is used and shared online.
We value the privacy of everyone who visits our site https://www.sigmafinancial.ai.
We will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the EU Regulation 2016/679 –the General Data Protection Regulation (“GDPR”);
means any person who publishes information on publicly available websites;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679– the General Data Protection Regulation (“GDPR”); and
Https://www.sigmafinancial.ai is aSite operated by Sigma Financial Trading Limited. We are registered in Englandunder company number 13634130, and have our registered office at 2.2.01 The Leather Market,Weston Street, London SE1 3ER.
2. Information About Us
2.1 Our Site isowned and operated by Sigma Financial Trading Limited, a limited companyregistered in England under company number 13634130, and have our registeredoffice at 2.2.01The Leather Market, Weston Street, London SE1 3ER.
2.2 Our DataProtection Officer is Claire Olejnik and can be contacted email@example.com
3. What Does This Policy Cover?
4. Your Rights
4.1 As a datasubject, you have the following rights under the GDPR, which this PrivacyPolicy and Our use of personal data have been designed to uphold:
4.1.1 The right to beinformed about Our collection and use of personal data;
4.1.2 The right ofaccess to the personal data We hold about you (see section 12);
4.1.3 The right torectification if any personal data We hold about you is inaccurate orincomplete (please contact Us using the details in section 13);
4.1.4 The right to beforgotten – i.e. the right to ask Us to delete any personal data We hold aboutyou (We only hold your personal data for a limited time, as explained insection 6 but if you would like Us to delete it sooner, please contact Us usingthe details in section 13);
4.1.5 The right torestrict (i.e. prevent) the processing of your personal data;
4.1.6 The right todata portability (obtaining a copy of your personal data to re-use with anotherservice or organisation);
4.1.7 The right to object to Us using your personaldata for particular purposes; and
4.1.8 Rights withrespect to automated decision making and profiling.
4.2 If you haveany cause for complaint about Our use of your personal data, please contact Ususing the details provided in section 13 and We will do Our best to solve theproblem for you. If We are unable to help, you also have the right to lodge acomplaint with the UK’s supervisory authority, the Information Commissioner’sOffice, at www.ico.org.uk/concerns.
4.3 For furtherinformation about your rights, please contact the Information Commissioner’sOffice or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or allof the following personal and non-personal data (please also see Our CookiePolicy):
5.2 business/company name
5.3 job title;
5.5 contactinformation such as email addresses and telephone numbers;
5.6 demographicinformation such as post code, preferences, and interests;
5.7 web browsertype and version;
We also crawl and index publicly available information (includingdata) from the Internet. We also contract directly with third party providersto gain access to their information (including data). In each case, theinformation that we have access to is published or made available by Creators.This information is then collated and stored in our database. We offer accessto our database, as well as analytics of the data within that database, tothird parties (our “Services”).
Since all of the information that we access is publiclyavailable, the raw information we have about you could be found by anybody withaccess to the Internet. Some of this information is personal data. For exampleyour name or username in connection with your Twitter or Facebook profile wouldbe personal data. Other information we process may not be personal data (forexample if you publish an anonymous review on a website).
As Creator, you are the source of the data. You have control overthat data within the platform you choose to publish it on, including throughusing the privacy settings made available to you by that platform. In additionto whatever rights you have via your relationship with any publishing platform,you also have certain rights relating to your data that we process, as set outin this Privacy Statement.
The data we collate from Creators depends upon the source of thedata, what the source or platform chooses to make available to us, plus what aCreator chooses to make available. It could include the following:
5.8 Name,username, handle or other identifier;
5.9 The contentof the information you have published via that name, username, handle, or otheridentifier, including comments, expressions, opinions, posts, etc.;
5.10 Your profilepicture or other images or videos that you post or interact with;
5.11 Your job titleor profession (including category of profession, for example “journalist”;
5.12 Your interests;
5.13 Your location;
5.14 Your gender;and
5.15 Any otherinformation you publish on an Internet website we crawl or on a third partyplatform that provides us with data.
We may also analyse the content of the data you publish and provide our analysis to our customers. For example, if you publish a Tweet stating that you like a certain brand’s ice cream, we may mark that Tweet as having a positive sentiment toward that brand.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use the data identified in Clauses 5.1 to 5.7 for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Replying to emails from you;
6.2.6 Analysing your use of Our Site and gathering feedback to enable Us to continually improve OurSite and your user experience.
6.3 The legal basis for the processing of the data identified in Clauses 5.8 to 5.15 is pursuant to our legitimate interests. Our legitimate interests are in providing our Services to our customers, which includes providing technology that empowers our customers to act with more certainty in a way that is easy-to-access and use. In turn, this allows our customers to learn more about their brand, their markets, their competitors, and other information available on the social web that is relevant to our customers.
6.4 We also use the data in ways related to, but ancillary, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties. We may also use the data to improve our Services.
6.5 Although it is the responsibility of our customers to use our Services properly, we do put in place safeguards to protect your data. We require our customers to comply with applicable law, including data privacy law, when using our Services. We also prohibit our customers from using our Services, including your data, in away that is outside of your reasonable expectations.
6.6 When we infer data about you, we do so automatically. The inferences are based on algorithms that analyse the data that you have posted. We do not make any decisions aboutyou based on the data that we process about you (inferred or not). In otherwords, we only make the data available to our customers. It is up to ourcustomers what (if anything) to do with the data and any inferences about thedata
6.7 We do notkeep your personal data for any longer than is necessary in light of thereason(s) for which it was first collected. Data will therefore be retained forthe following periods (or its retention will be determined on the followingbases):
6.7.1 Data identifiedin Clauses 5.1 to 5.7 for a period of 6 years, in accordance with theLimitation Act 1980;
6.7.2 Data identifiedin Clauses 5.8 to 5.15 will be retained for as long as it is reasonablynecessary for us to provide the Services.
However, if you request that we delete your data, or if youdelete your data from the platform in which it was originally published, wewill also delete your data from our Services.
7. How and Where Do We Store Your Data?
7.1 We only keepyour personal data for as long as We need to in order to use it as describedabove in section 6, and/or for as long as We have your permission to keep it.
7.2 We maytransfer your data to, and store it in, a country other than your own. Thatcountry may not provide the same level of data protection as your own country.Whenever we transfer your information outside of Europe, we will take stepswhich are reasonably necessary to ensure that adequate safeguards are in placeto protect your personal information and to make sure it is treated securely.If you are located in Europe, you may contact us for a copy of the safeguardswhich we have put in place to protect your personal information and privacyrights in these circumstances.
7.3 The serversin which we hold your data have appropriate administrative, technical, andphysical controls that are designed to safeguard your data, includingindustry-standard encryption technology.
8. Do We Share Your Data?
8.1 In addition to sharing the data identified in Clauses 5.8 to 5.15 with our customers, in certain circumstances, We may be legally required to share certain data held byUs, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How CanYou Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and bymanaging your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK:The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“theMPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. YourRight to Withhold Information
12. How CanYou Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 13.
15. Definitionsand Interpretation
means a small file placed on your computer or device by Our Sitewhen you visit certain parts of Our Site and/or when you use certain featuresof Our Site;
means the relevant parts of the Privacy and ElectronicCommunications (EC Directive) Regulations 2003 and of EU Regulation 2016/679General Data Protection Regulation (“GDPR”);
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by EURegulation 2016/679 General Data Protection Regulation (“GDPR”); and
Our Site is owned and operated by Sigma Financial Trading Limited, a limited company registered in England under company number 13634130 and have our registered office at 2.2.01 The Leather Market, Weston Street, London SE1 3ER.
16. Information About Us
2.1 Our Site is owned and operated by Sigma Financial Trading Limited, a limited company registered in England and Wales under company number 13634130 and have our registered office at 2.2.01 The Leather Market, Weston Street, London SE1 3ER.
2.2 Our DataProtection Officer is Claire Olejnik, and can be contacted by email at email@example.com
3.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We useCookies to facilitate and improve your experience of Our Site. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
3.2 By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site, for more details, please refer to section 4 below.
3.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
3.3.1 Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
3.3.2 Analytics Cookies
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
3.3.3 Functionality Cookies
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
3.3.4 Targeting Cookies
It is important for Us to know when and how often you visit OurSite, and which parts of it you have used (including which pages you havevisited and which links you have visited). As with analytics Cookies, thisinformation helps us to better understand you and, in turn, to make Our Siteand advertising more relevant to your interests. Some information gathered bytargeting Cookies may also be shared with third parties.
3.3.5 Third PartyCookies
Third party Cookies are not placed by Us; instead, they areplaced by third parties that provide services to Us and/or to you. Third partyCookies may be used by advertising services to serve up tailored advertising toyou on Our Site, or by third parties providing analytics services to Us (theseCookies will work in the same way as analytics Cookies described above).
Any of the above types of Cookie may be a persistent Cookie.Persistent Cookies are those which remain on your computer or device for apredetermined period and are activated each time you visit Our Site.
3.3.7 Session Cookies
Any of the above types of Cookie may be a session Cookie. SessionCookies are temporary and only remain on your computer or device from the pointat which you visit Our Site until you close your browser. Session Cookies aredeleted when you close your browser.
3.4 Cookies onOur Site are persistent, and will expire after no more than two years ofinactivity, i.e. every time you visit Our Site, this extends theexpiration to two years from the latest date.
3.6 For morespecific details of the Cookies that We use, please refer to the table below.
18. WhatCookies Does Our Site Use?
4.1 Our Site usesanalytics services provided by Google. Website analytics refers to a set oftools used to collect and analyse anonymous usage information, enabling Us tobetter understand how Our Site is used. This, in turn, enables Us to improveOur Site and the services offered through it. You do not have to allow Us touse these Cookies, however whilst Our use of them does not pose any risk toyour privacy or your safe use of Our Site, it does enable Us to continuallyimprove Our Site, making it a better and more useful experience for you.
4.2 The analyticsservice(s) used by Our Site use(s) analytics Cookies to gather the required information.
4.3 The analyticsservice(s) used by Our Site use(s) the following analytics Cookies:
19. Consentand Control
5.1 BeforeCookies are placed on your computer or device, you will be shown a pop-uprequesting your consent to set those Cookies. By giving your consent to theplacing of Cookies you are enabling Us to provide the best possible experienceand service to you. You may, if you wish, deny consent to the placing ofCookies unless those Cookies are strictly necessary; however certain featuresof Our Site may not function fully or as intended.
5.2 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
5.3 The links belowprovide instructions on how to control Cookies in all mainstream browsers:
5.3.1 Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
5.3.2 MicrosoftInternet Explorer: https://support.microsoft.com/en-us/kb/278835
5.3.3 Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge
(Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
5.3.4 Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
5.3.5 Safari (iOS): https://support.apple.com/en-gb/HT201265
5.3.6 Mozilla Firefox:https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
5.3.7 Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)