Ikon Finance Limited ("IKON"), believes that maintaining our clients trust and confidence is a high priority. We understand that privacy and how we protect personal data and confidential information is an important concern for both clients and visitors to our website(s).
Personal Data We Collect
In order to provide you with financial products and services, or information about such services, we may collect the following types of Personal Information:
- Information we receive from you on account applications, whether written or electronic, or on other forms (including on-line forms) and every time you email us or provide us with your details in other ways (i.e. over the telephone, by fax, by mail etc.).
- This information would include, but not be limited to, such details as: your name, address, landline or mobile telephone numbers, fax number, e-mail address, location derived from IP address, social security or national insurance number, tax identification number, your date of birth; employment details, company name and contact details; income, investment experience; government issued identification documents such as passports driving licenses, national ID’s; details of the ways in which you are happy to receive information from us and/or selected third parties etc.
- Information about your transactions with us, our affiliates, or others. This information could include your trading history through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
- Information about you obtained in connection with our efforts to protect against fraud or unauthorised use of your account(s) with us.
- Information automatically collected about your visit to our website.
- Information relating to your selection of a user ID for the use of some of our services or activities.
You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.
Use of Personal Data We Collected
We hold your personal information in order to open and manage your account with us, whilst also satisfying the key regulatory obligation of "Know your client" (“KYC”) and Anti-Money Laundering (“AML”). In addition, this information enables us to review your needs on a regular basis thereby assisting us in providing you with the level of customer service you expect. IKON uses the data we collect in the following ways:
- To perform essential business operations (including monitoring and improving) and provide the products and services we offer;
- To perform administration on the account you may hold with us on an on-going basis, including keeping records we hold accurate and up-to date;
- Process certain personal information about you, officers, authorised dealers, directors, shareholders, ultimate beneficial owners (if applicable) or any other associated employees in order to carry out anti-money laundering and international terrorist financing checks and related actions which we consider appropriate to meet any legal obligations imposed on us relating to, or to pursue our legitimate interests in relation to the prevention of fraud and other forms of crime (money laundering, terrorist financing, bribery and corruption, tax evasion, cyber-crime) and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions. We may also process your information to detect and prevent scalping, market abuse, or any other unethical trading in accordance with our existing policies and procedures.
- We use the data to carry out analysis and monitoring that enable us to operate, fulfil our legal and regulatory responsibilities and obligations including regulatory and supervisory reporting, make informed decisions, and report on the performance of our business. This includes disputes/complaints handling and resolution, reporting tax related information to tax authorities, record retention for screening purposes, etc. to pursue our and in some circumstances our clients’ legitimate interests.
- To monitor and record telephone conversations and electronic communication for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend our rights, ourselves or through delegation of such responsibilities or rights to third parties in order to comply with a legal obligation imposed on us or to pursue our legitimate interests in relation to such matters or the processing in the public interest.
- We use data we collect to communicate with you and personalise our communications with you. For example, we may contact you by phone or e-mail or other means in order to respond to your query we may receive via our website, e-mail, client portal, chat system or by phone.
- To effectively communicate and deliver information to you, including marketing and promotional communications about products and services that may be of interest to you or the institution you represent. Where we send you these communications we will either do so for the purposes of the legitimate interests pursued by us or with your consent.
- For any processing that is necessary to perform a relevant contract with you, comply with our legal obligations and/or which is necessary for our legitimate interests as set out above and/or where processing is necessary for reasons of public interest.
Information We May Disclose
The personal data we hold about you is confidential, will be treated as such and used in accordance with the use outlined above.
We may disclose your personal data where and when necessary in conduct of our business operations providing you with our products and services. In disclosing your personal data, we will do so in accordance with General Data Protection Regulation (“GDPR”), all other relevant data privacy laws and our internal policies.
We may share/disclose your personal data with:
- Our third-party service providers where necessary to perform the service they provide for us such as software and platform support etc
- Companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell IKON’s products or services. We will seek your express consent before disclosure for marketing purposes;
- Financial service providers, such as broker-dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisors, and commodity pool operators;
- Government bodies and law enforcement agencies;
- Successors in title to our business;
- We may also disclose Personal Information to other non-affiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorised,
- Anyone authorised by you
Your Rights as Data Subject
The GDPR provides the following rights for you:
- The right to be informed – If you ask us, we will provide you with various pieces of information about the data processing activities undertaken by us.
- The right of access – If you make a request, we will provide you with confirmation whether your personal information is being processed by us and a copy of that personal information.
- The right to rectification – If the data we hold about you is inaccurate or incomplete you have the right to rectify it. If we have disclosed your information to others for the purposes described in this notice, we will inform them about the rectification where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
- The right to data erasure (the right to be forgotten) – You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it and we have no compelling reasons or legal basis for holding it or, where applicable, you withdraw your consent. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will inform them about the erasure where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
- The right to restrict processing- In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
- The right to data portability – This allows you, in certain circumstances, to obtain personal information you have provided us with and move, copy or transfer it between service providers of your choice.
- The right to object- You can ask us to stop processing your personal information and we will do so, if:
- Processing is based on our legitimate interests, except if we can demonstrate overriding compelling legitimate grounds to continue processing or the processing is for the establishment, exercise or defence of legal claims;
- Processing is for direct marketing; and
- Processing is for purposes of historical research and statistics
- You can choose whether you wish to receive promotional e-mails or telephone calls from us. You can also opt out of (or unsubscribe from) receiving marketing emails at any time by clicking on the unsubscribe link at the bottom of the latest email you received from us.
- Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision when:
- it is based on automated processing; and
- it produces a legal effect or a similarly significant effect on you.
- Right to Complaint
If you have opted out of receiving any marketing communications from us we will add you to a “do not contact” list to ensure we comply with your opt-out right and that your details will not be put back on the marketing list at later stages.
International Transfer of Personal Data
Your personal data may be transferred, stored, processed and or used in a country outside the European Economic Area (“EEA”). You should be aware that countries outside the EEA do not always have strong data protection laws or offer the same level of protection as those in the EEA
However, in the event any personal data transfer is made to countries outside of the EEA, we will ensure that it is kept secured and that it is done only to organisations with the appropriate level of data security having complied with our legal obligations and standards such as entering into binding and enforceable contracts prescribed under GDPR.
We will retain personal data for as long as necessary to provide you with our products and services, and/or for other essential business and legal purposes for which data was collected, depending on the legal basis for which that data was obtained and whether we are under any additional legal or regulatory obligations to retain your personal information.
Because these needs can vary for different data types in the context of different legal and regulatory requirements, actual retention periods vary. When we longer need personal data, we will securely destroy it.
Security of Information Collected
To protect the security of Personal Data, we maintain physical, electronic, and procedural safeguards that comply with regulatory standards for securing the information we collect about you.
Whereas we employ reasonable measures to protect against viruses and other harmful components, the nature of the internet is such that it is impossible to ensure that your access to the Web site will be uninterrupted or error-free, or that this Web site, its servers or emails which may be sent by us are free of viruses or other harmful components.
Whether you are a IKON client or a visitor browsing our web sites, and you submit / request information from one of our non-public areas (login & password / token protected areas) such as our online account forms, or trading statements please note that we use Secure Sockets Layer ("SSL") encryption technology to protect the information you submit. This technology helps protect you from having your information intercepted by anyone other than IKON while it is being transmitted to us. We strive to ensure that our web sites are and remain secure and that they meet the highest possible industry standards. In addition to SSL encryption technology, we use a variety of other safeguards such as firewalls, authentication systems (e.g. passwords, tokens etc) and access control mechanisms to control unauthorised access to our systems and data.
Please be assured that all information we gather by the use of a cookie is compiled on an aggregate, anonymous basis. With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. If you want to know how to do this, please look at the help menu on your web browser.
You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may not be able to use certain features on our site have to manually adjust some preferences every time you visit our website or use our Platform and some services and functionalities we offer may not work.
Contacting Us About This Policy or Making a Complaint
If you are however, dissatisfied with our response or believe we are not processing your personal data in accordance with GDPR and related regulations/laws you can escalate this to the UK’s Information Commissioner’s Office (ICO).
The ICO can be contacted:
Address: 75-77 Great Portland Street, London W1W 7LR
Telephone: 0303 123 1113