Effective Date: 28 January 2021
Our Website has been developed and is operated by Vertree Partners Limited of 2nd Floor, Cardinal Place, 100 Victoria Street, London, Greater London, SW1E 5JL who is the controller of your personal data processed in connection with our Website.
2. Types of Information Collected
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you as follows:
- Contact Data includes name, address, email address and telephone number.
- Employment Data includes company you work for and job title.
- Transaction Data includes details about products or services your request from us.
- Technical Data includes information about how you use our website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. Purposes for processing your personal data
We may process any personal data you provide to us to enable us to perform the contract entered into between you and us, to ensure our compliance with legal and regulatory requirements or for the purposes of our legitimate business interests, including the following:
- to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us;
- to enable us to respond to an enquiry or other request you make when you contact us via our Website, including for customer services support;
- to comply with our legal obligations, standards, policies and procedures;
- to notify you about changes to our service;
- to enable us to issue a notice or corrective action to you in relation to any of our services, if required;
- to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective manner; and
- to communicate and provide you with the relevant market information you have requested in our newsletters (by email).
We may also use your personal data to send you marketing-related information (such as newsletters) from Hartree Partners where it is linked to the service we are providing you. You may unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of each marketing communication.
Please note that where you opt-out of receiving marketing communications, we may still send you certain communications relating to your use of our service, such as service announcements, notices about information on the service and administrative messages.
5. Sharing your personal data
We may share your personal data with:
- our affiliated companies;
- Government bodies and agencies in your jurisdiction and overseas (for example, the UK Financial Conduct Authority) to comply with our legal and regulatory obligations;
- our service providers that we engage to provide services for us. Where we provide your personal data to third party services providers, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by
We may also disclose your personal data where required to respond to authorized requests from government authorities or where required by law, including for national security. Where required by law, we may also disclose your personal data where necessary to enforce or apply our Website Terms or other agreements, to investigate or protect the rights, property or safety of Hartree Partners and our group companies, our products and services and our personnel, customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation or investigations.
6. Keeping your Personal Data Secure
The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet and any transmission is at your own risk.
7. Storing your Personal Data
Your personal data collected via our Website will be stored on servers located in the United Kingdom. It may also be processed by, and transferred to, Hartree Partners staff or by one of our service providers operating in the United States, India or Singapore. This includes individuals engaged in, among other things, administration of an enquiry or request you make via our Website or the provision of support services.
We have implemented appropriate safeguards, to protect your personal data when it is transferred. Please contact our Hartree Data Protection Group by email at GDPR@hartreepartners.com if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom or European Economic Area or by mail at Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036 for the attention of Hartree Legal (Data Protection Group).
We will only retain your personal information 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. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your Rights
You may inform us of any changes to your personal data, and in accordance with our obligations under applicable data protection laws we will update or delete your personal data accordingly. To find out what personal data we hold on you or to have your personal data updated, amended or removed from our database, please contact us using our contact information below.
Residents of the United Kingdom and European Economic Area (‘EEA’): You may have the right to: request (a) access the to your personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company. You also have the right to lodge a complaint about how we process your personal data with the supervisory authority for data protection issues in your country.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
To exercise any of your rights in connection with your personal data, please contact our Hartree Data Protection Group by email at GDPR@hartreepartners.com or by mail to Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036 for the attention of Hartree Legal (Data Protection Group). We will process any request in line with any local laws and our policies and procedures.
9. Third-Party Links
11. Contact Us
If you have any questions about the processing of personal data via this Website, please contact our Hartree Data Protection Group by email at GDPR@hartreepartners.com or by mail to Hartree Partners, LP of 1185 Avenue of the Americas, New York, NY 10036 for the attention of Hartree Legal (Data Protection Group). If you contact us, we will do our utmost best to address any concerns you may have about our processing of your personal data.