Quadrature office breakout space

Privacy Notice

For our Candidate Privacy Notice, please click here.

WHAT IS PERSONAL DATA?

The term personal data describes any information relating to an individual, where the individual is identified or identifiable, directly or indirectly, by reference to that information.

Examples of personal data include:

  • names;
  • residential addresses;
  • email addresses such as name.surname@company.com;
  • identification card numbers;
  • location data (for example the location data function on a mobile phone); and
  • internet protocol addresses.

HOW WE COLLECT INFORMATION ABOUT YOU

We may collect personal data about you through:

  • information provided by you directly to us or by another person acting on your behalf:

    • through our website;
    • by email;
    • by post;
    • by telephone; or
    • in person,
  • information that we obtain in relation to any transactions between you and us;
  • recording and monitoring of telephone conversations and electronic communications with you as described below; or
  • the use of Internet “cookies”, as described further below.

We may also, in some circumstances, receive personal data about you from third parties, such as current or prospective service providers, trading counterparties, regulatory or law enforcement agencies, credit reference agencies, or agencies conducting background checks. Personal data may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

WHY WE COLLECT INFORMATION ABOUT YOU

We may collect and use your personal data for the purposes of managing the relationship between you and us, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will not sell your personal data or use it for direct marketing purposes.We will use one of the permitted legal bases for collecting and processing personal data, as set out in the EU General Data Protection Regulation (“GDPR”). Such bases include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a contract or other legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal data.

The legitimate interests to collect your personal data may include any purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or process your personal data for such purpose.

You may request more information on the legal basis for collecting and processing your data when we request personal data from you and you have the right to object to the use of your personal data by us.

WHAT ARE THE CONSEQUENCES OF FAILING TO PROVIDE YOUR PERSONAL DATA?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal data , such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below). We may also need to collect and use your personal data for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal data may, depending on the purpose for which your personal data is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

THE TYPES OF PERSONAL DATA WE MAY COLLECT AND USE

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).

DO WE USE AUTOMATED DECISION-MAKING PROCESSES?

No.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We may (to the extent necessary for the purposes for which we collect your information), share your personal data with third parties, such as:

  • our affiliates, including Quadrature Climate Foundation, or other entities that are part of our group, or with our clients;
  • any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
  • our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
  • service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
  • credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
  • any person, as directed by you; or
  • any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

TRANSFERS OF PERSONAL DATA TO COUNTRIES OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including jurisdictions that may not have the same level of data protection as that afforded by the GDPR or other data protection rules applicable to us (collectively, ”Data Protection Law“). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will generally keep personal data about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period as required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

WHAT ARE YOUR RIGHTS?

IF YOU ARE IN THE UK OR THE EU:

If you are a resident of the UK or the EU, you have the following rights, including the right to:

  • request that we provide you with a copy of your personal data (you will receive your data in a structured, machine readable format);
  • request that we correct the personal data we hold about you (if the data is inaccurate, incomplete or otherwise incorrect);
  • request that we delete the personal data we hold about you (where we have no legitimate reason to keep the data or you’ve exercised your legal right to object to processing);
  • object to processing in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement)
  • request the restriction of processing of your personal data, which enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
  • request the transfer of your personal data to another person.

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Quadrature processing your data, this will not affect any processing which has already taken place at that time. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) contact us at +44-20-3743-0400; (ii) submit a webform request here or (iii) send an email to privacy@quadrature.ai.

We will confirm receipt of your request within five days, and we will respond within 30 days (or, if your request is complex or we receive numerous requests within a short period of time, within 90 days). Any information will be provided to you free of charge.

IF YOU ARE A RESIDENT OF BRAZIL:

If you are a resident of Brazil, you have the following rights, including the right to:

  • request confirmation of whether we process your personal data;
  • request that we provide you with access to a copy of your personal data;
  • request that we correct the personal data we hold about you (if the data is inaccurate, incomplete or outdated);
  • request that we anonymise, block or delete unnecessary or excessive data or data that is not being processed in compliance with applicable law;
  • request that we port your personal data to another service or product provider, by means of an express request and subject to limitations under applicable law;
  • request that we delete the personal data we hold about you, except where we are permitted to retain such data under applicable law;
  • request information about the public and private entities with which we have shared your personal data; and
  • request information about the possibility of denying consent and the consequences of such denial.

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Quadrature processing your data, this will not affect any processing which has already taken place at that time. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) contact us at +44-20-3743-0400; (ii) submit a webform request here or (iii) send an email to privacy@quadrature.ai.

We will confirm receipt of your request within five days, and we will respond within 15 days if the data requested is not in simplified format. Any information will be provided to you free of charge.

IF YOU ARE A RESIDENT OF CALIFORNIA:

If you are a resident of California, you have certain consumer rights under the California Civil Code and applicable California privacy laws, which may be subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:

  • request that we disclose information about (i) the categories of personal data collected; (ii) the sources from which the personal data was collected; (iii) the business or commercial purpose for collecting the data; (iv) the categories of third parties with whom we share the information; and (v) the specific pieces of personal data we collect about you;
  • request that we delete your personal data; and
  • opt out of the sale of your personal data.

We do not, and will not, sell your personal data and you will never receive discriminatory treatment for exercising your privacy rights.

You may use an authorised agent to submit a request on your behalf in relation to the rights listed above. When using an authorised agent, we will require that you provide your agent with written permission to do so, and verify their own identity and agent status with us. If you would like to designate an authorised agent to make a request on your behalf, please email us at privacy@quadrature.ai.

We may need to verify the identity of a person making a request under this section and this may require that we request further information on the person making a request. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For requests to know and requests to delete, we will confirm receipt of the request within 10 days and provide information about how the business will process the request, and we will respond within 45 days (or, if your request is complex or we receive numerous requests within a short period of time, within 90 days). Any information will be provided to you free of charge.

Please note that we cannot provide you with information on your data more than twice in a 12-month period.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) contact us at the toll-free telephone number +1 833 7474784; (ii) submit a webform request here or (iii) send an email to privacy@quadrature.ai.

HOW TO CONTACT US

Please contact us on +44(0) 20 3743 0400, by email at privacy@quadrature.ai or by writing to the following address Quadrature Capital Limited, The Leadenhall Building, 122 Leadenhall Street, London, EC3V 4AB for any questions about this privacy notice or requests with regards to the personal data we hold.

COMPLAINTS

If you have unresolved concerns, you have the right to complain to your local data protection authority. The UK’s data protection authority is the ICO and you can make complaints at https://ico.org.uk/make-a-complaint/. Further information is available on the ICO’s website.

USE OF COOKIES

Our policy regarding the use of cookies on this website can be found here.

RECORDING AND MONITORING OF COMMUNICATIONS

We record and monitor telephone conversations and electronic communications (including emails) with you for the purposes of:

  • ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
  • ensuring compliance with our regulatory obligations; or
  • detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of seven years, or such other longer period as we (or relevant legislators or regulators) may determine from time to time.

UPDATES TO THIS PRIVACY NOTICE

This privacy notice will be updated at least annually. We will update the date at the bottom of this privacy notice accordingly and encourage you to check for changes to this privacy notice. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this privacy notice, as required by applicable law.

Effective from 5 August 2020