Privacy Policy

This Privacy Policy applies as between you, the User of this Website and TWOFOX Limited, the owner of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website and any Services or Systems therein.

2.1. Our website is not intended for use by minors and we do not knowingly collect data relating to minors

2.2. This Policy is supplemental to our other Policies and Agreements (including, but not limited to, the Terms and Conditions Agreement found which can be found at www.twofoxtrading.co.uk/resources/legal/terms-and-conditions.

2.3. TWOFOX Limited is the controller and is responsible for your personal data.

2.4. To assist you further in understanding this Privacy Policy, we have set out in Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

2.5. We have appointed a data privacy manager. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPM in writing, via email at admin@twofoxtrading.co.uk.

2.6. You have the right to make a complaint at any time to the ICO (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.

2.7. It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

2.8. Our website may include links to third-party websites, plug-ins, and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug in or applications and are not responsible for their privacy policies, therefore you should also read their privacy policy to understand what personal data they collect about you and how they use it.

3.1. We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.

3.2. We also collect, use, and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

3.3. We do not collect any Special Data.

3.4. If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into / perform the contract with you and, as such, we may have to cancel a product or service. We will notify you of this at the relevant time.

We collect personal data in the following ways:

5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

5.2. Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

5.3. We do generally only rely on consent as a legal basis for processing your personal data to send email marketing communications and you have the right to withdraw your consent at any time by contacting us. Please 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 information.

5.4. We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.

5.5. We will not share your personal data with third parties for their marketing purposes.

5.6. You can opt out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM at admin@twofoxtrading.co.uk.

5.7. Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

5.8. We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

5.9. 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 use your personal data in this manner.

5.10. We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

We may have to share your personal data with third parties, further details of which are set out in Part 4 of Schedule 1. 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. They can only process your personal data for specified purposes and in accordance with our instructions.

7.1. TWOFOX Limited Website hosting and storage is located within the European Union, whilst TWOFOX Limited is located within the United Kingdom (UK), as such, using our Website, Products and/or Services may involve the transfer of data between the UK and the European Economic Area (EEA).

7.2. Should it, at any time, become necessary to transfer your personal data anywhere other than the UK or the EEA, we will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the UK and/or the European Commission.

7.3. We may also transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

7.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

7.5. Details of international data transfer specific to the ‘Google Analytics’ third-party service are set out in Schedule 2.

8.1. 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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.

8.2. We have procedures in place 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.

9.1. 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.

9.2. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.

9.3. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

10.1. You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.

10.2. You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive, and/or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

10.3. We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

10.4. 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.

TWOFOX Limited reserves the right to 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 the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

TWOFOX Limited may set and access Cookies on your computer, refer to the Cookie Policy, found at www.twofoxtrading.co.uk/resources/legal/cookie-policy for details.

13.1. Our website uses third-party services and/or content to help us provide you with the best user experience, we also use third-party services to help develop our business, inform our marketing strategy and to keep our website updated and relevant to our customers.

13.2. In order to perform the requested service or to deliver the requested content, the Third-Party Provider typically requires technical data from you, the user, including, but not limited to, your IP address.

13.3. TWOFOX Limited has no influence or control over how and for what purpose your data may be stored and/or used by any Third-Party-Provider.

13.4. A list of Third-Party-Providers, including details of the service(s) and/or content provided, is set out in Schedule 2.

13.5. With the exception of ‘Google Analytics’, the third party content and/or services are necessary, either for the proper functioning of the website, or to perform a legitimate business activity, as such, the legal basis for data processing is established based upon UK/EU GDPR Article 6, paragraph 1, point (f).

13.6. The ‘Google Analytics’ service is not necessary for the proper functioning of the website but does perform a legitimate business purpose in aiding us to develop our services and provide you with an improved user experience.

13.7. Our implementation of ‘Google Analytics’ is configured such that IP addresses are anonymized by ‘Google Analytics’ as soon as technically feasible. The process of IP address anonymization is explained in detail at support.google.com/analytics/answer/2763052.

13.8 If you have privacy concerns regarding the use of ‘Google Analytics’, then you may refuse or revoke consent, by either following the instructions found in Section 4. of the Cookie Policy, ‘Disabling / Deleting Cookies on / from Your Computer’, or by installing the Google Analytics Opt-out Brower Add-on (Google developed add-on specifically for inhibiting ‘Google Analytics’) found at tools.google.com/dlpage/gaoptout.