Privacy Policy

Privacy Notice

This privacy notice tells you what to expect us to do with your personal information when you make contact with us or use one of our services. In summary:

  • We keep to a minimum the amount of information we hold about you.
  • We use your data to respond to your enquiries about our services and send you other useful information (the lawful basis for this is “legitimate interest”) and to provide our services to you (the lawful basis for this is “Performance of a contract”).
  • We delete your data when it is no longer needed.
  • We apply appropriate security mechanisms to protect your personal data.
  • We ensure any third party processors have sufficient safeguards in place.

Who are we?

We are Fnality International Limited of 2 Minster Court, Mincing Lane, London, EC3R 7BB, United Kingdom.

We are creating a network of decentralised financial market infrastructures to provide the means of payment-on-chain for tomorrow’s wholesale financial markets.

Privacy contact: peopleops@fnality.org

How do we get your personal information? 

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • You have made an enquiry to us.
  • You have submitted a form.
  • You wish to attend, or have attended, an event.
  • You subscribe to our e-newsletter.

The kinds of personal information we collect about you depends on the reasons for the collection, and may include your name, contact details, your dietary preferences, and other information that identify you. Our lawful basis for holding this information is either for the purposes of a contract with you, in our legitimate business interest or for the purposes of meeting a legal obligation. A detailed breakdown of how we process data and what the specific lawful basis used is defined in our Privacy Policy.

How do we use your personal data?

We’ll use your personal information to respond to your queries about our business and to provide you with products and services.

We’ll use your personal information if we consider it is in our legitimate business interests so that we can operate as an efficient and effective business.  We use your information to:

  • identify, and let you know about, products, services and business opportunities that may interest you;
  • share within the Fnality Group, including its shareholders, for administrative purposes;
  • create aggregated and anonymised information for further use;
  • detect and prevent fraud; and
  • secure and protect our systems. 

In some cases, we may use your personal information to create aggregated and anonymised information. Nobody can identify you from that information and we’ll use it to:

  • run management and corporate reporting, research and analytics, and to improve the business; and
  • provide other organisations with aggregated and anonymous reports.

We may have to release personal information about you to meet our legal and regulatory obligations.  For example under a court order or where we cooperate with other European supervisory authorities in handling complaints or investigations.

Use of Third Party Platforms: 

This website uses a HubSpot tracking code which uses cookies or similar technologies to track visitors. We use the information gathered to improve our website functionality, the user experience and content.

hubspot log files

HubSpot uses log files. Log files may collect demographic information from you, for example, address, age, gender or interests. They may also collect information about your computer hardware and software. This can include your IP addresses, device and software identifiers, referring and exit URLs, on-site behaviour, feature use metrics and statistics. This information is used for the Subscription Service. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.

Hubspot Navigational Information 

We may collect navigational information when you visit HubSpot hosted web pages on our website. The navigational information is used to improve your experience of using the website and to ease navigation around the site.

To find out more about HubSpot, please review their privacy policy and their security guidance.

The HubSpot Acceptable Use Policy applies to our website and prohibits the use of our website to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service to have an "opt-out" mechanism.

Pages of our website are hosted in England and by HubSpot whose registered address is: 25 First Street, 2nd Floor, Cambridge, MA 02141, USA. Data captured and obtained within the UK, may be processed outside of the UK.

hubspot linkedin tracking

This website uses a LinkedIn tracking code which uses cookies or similar technologies to track visitors of this website and gathers information about them related to their LinkedIn profile. We use the information gathered to improve our website functionality, user experience and tailor content. This data is used to deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.

For more information about LinkedIn’s privacy policy, click here.

This website uses Google Analytics, a web analytics service offered by Google Inc. Google Analytics will make use of small pieces of data, known as cookies, which can be used to track and analyse the manner in which you use and operate our website. Such data might be transferred to, and stored on, a server in the USA operated by Google, Inc. Google, Inc. may transfer this data to third parties where required by law, or other third party processors used by Google, Inc. You may prevent cookies from being stored in relation to your visit to, and use of, our website but do please be aware that this may negatively impact upon the way in which the website works.

Sharing your information

We use data processors who are third parties who provide services and other support to us. We have contracts in place with our data processors. This means that they may not legally do anything with your personal information unless we have instructed them to do it.

Your data protection rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

Your right of access

You can access and update the information we hold about you by making a request to us at peopleops@fnality.org.  Once we’ve looked at your request, we’ll let you know when you can expect to hear from us.

We’ll always try to help you with your request and even though we will endeavour to complete your request free of charge, we are allowed to reject requests if:

  • they’re repetitive;
  • you don’t have the right to ask for the information; or
  • the requests made are excessive.

If we decide not to process your request, we'll explain why.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure

You have the right to ask us to erase your personal information. This is not an absolute right and whilst we will always endeavour to meet this request there may be circumstances that make this inappropriate.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing

You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests. 

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Please contact us at peopleops@fnality.org if you wish to exercise this right.

How long do we retain your data?

Marketing Information

2 years

We will store your personal information for a maximum of two years after your last communication with us, or from the date of completion of our services, whichever is the latest. If you wish to stop hearing from us prior to that time then email peopleops@fnality.org.

Financial Information

8 years

Financial transactions between us might include some personal data. We are required to keep this information for the current financial year plus an additional seven years.

Service Information

10 years

We may store your information in our databases, such as our customer relationship database, for reference. The information may be retained and used by us to answer queries or resolve problems, provide improved and new services and any data retention requirements of the law. This means we may retain information after an individual ceases to use our services.

Vacancy Application Information

6 months

In the event that you are unsuccessful for a role with us we generally retain your information for no longer than 6 months after we have notified you that you are unsuccessful for that role. However, we may, with your permission, keep your information on file and contact you again in the event that a suitable role appears for which you may be suitable in the future. In such circumstances, we would retain your information for no longer than two years.

Legal Requirements

 

In certain circumstances the law, authorities or regulatory bodies require us to retain data for longer.

How to contact us and further details

If you’d like any more details, or you have comments or questions about our privacy policy, You can get in touch with our Privacy Team by email at peopleops@fnality.org.

If you want to make a complaint on how we have handled your personal information, please contact our Privacy Team who will investigate the matter and report back to you.  If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the data protection regulator in the country where you live or work.  For the UK, that’s the Information Commissioner - https://ico.org.uk/

Changes to this privacy notice

We review our privacy notice regularly. 26 November 2019. Fnality International Limited is registered with the UK Information Commissioner’s Office (ICO) under reference number ZA543069.