Privacy policy

Policy purpose

Next Gate Tech S.A. and its subsidiaries (“Next Gate Tech”, “NGT”, “the Company”, “we”, “our” or “us”) are strongly committed to being responsible custodians of the information you provide to us and the information we collect in the course of operating our business.

This Privacy Notice applies to individuals outside of Next Gate Tech, including website (“Sites”) visitors, customers, authorised customer staff using our Dashboards, vendors, job applicants, and others (“you”). It applies when you visit our Sites, use our services, apply for jobs or placements, have a relationship with our clients, or where information is collected from third parties.

Our aim is to clearly explain the types of Personal Data we collect and process about you, the reasons for its use, and the entities with whom we share it. This policy ensures you are informed about your rights regarding your Personal Data and provides guidance on how to contact us with any questions or concerns.

Reviewing and updating

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

Collection of your personal data

Next Gate Tech collects certain personal data about you. We may obtain your personal data when you provide it to us (e.g., where you contact us via email or telephone, via our website or other means). If you are a customer or authorised staff of customers, we also obtain personal data from you in the ordinary course of our business relationship.

The Company respects your privacy and we commit to keeping your personal data secure.

Data you provide
- You or your employer may provide information to us, which includes information about you. The nature of our relationship with you will determine the kind of Personal Data we might ask for. Such information may include:
  - Personal identifiers, contacts and characteristics such as
  - full name;
  - email address;
  - phone number;
  - address (including city postcode and country);
  - occupation and job title;
  - Identity documentation; and
  - date of birth
Data we collect automatically
- Information we collect about you or that we may generate include:
  - Information that we may produce as a record of our relationship with our customers and prospective customers, including contact history; and any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements; or
  - We also collect or obtain online identifiers when you visit any of our Sites or Dashboards or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose
    certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.
Data we collect from third parties
- We may collect personal data from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third party data
  processors and sub processors.
- From the Website, in some cases, we collect data about you from other sources, such as trusted third parties, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us. We use this information to supplement the data we already hold, to better
  inform, personalise, and improve our services.
- After your written authorisation, we will collect data from your service providers (administrators, prime broker, brokers, custodian bank, etc.) NAV Details files, Transactions (Trades List, Trades Confirmations), NAV Summary, Key Performance Indicators, and raw data that will allow us to provide you with the services you
  require and are necessary for the performance of a contract.
- We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.

How we store your data

Data must be protected appropriately to its risk as well as its importance or value.

We ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non-public personal information and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested.

We have extensive controls and mechanisms in place designed to detect, respond and recover in case of adverse events that may arise.

You are responsible for ensuring that any Personal Data that you send to us is sent securely.

How we use your data

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

to allow customers and prospective customers to use and access Next Gate Tech services;
to respond to queries from customers and prospective customer applications or to provide application support to customers;
to set up / onboard prospective customers to use the Company’s services;
to keep our records up to date;
to monitor our technology systems in order to protect against cyber threats or malicious activity including abuse and misuse;
to protect against unauthorised website or system access or use, or any unlawful activity;
to administer or maintain technology systems to maintain service levels;
for ongoing review and improvement of the information provided on our Sites to make them user friendly and prevent potential disruptions or cyber attacks;
to analyze feedback on Next Gate Tech’s Services and to help provide more information on these services quickly and easily;
to communicate with and better understand the interests of customers and prospective customers in order to provide services or targeted information about the Company’s services;
to manage and develop customer and prospective customer relationships,
understand the respective needs and interests in order to develop, improve and manage the services we can offer;
offering similar products and services with respect to the services already provided to you in the context of direct marketing solicitation, notably via post, email, it being understood that you can object at any time, on request and free of charge, to the processing of your Personal Data which Next Gate Tech anticipates being processed for the purposes of direct marketing;
inviting customers and customer-related contacts to Next Gate Tech events (either physical or online events) or events endorsed or sponsored by Next Gate Tech, or events where Next Gate Tech is affiliated or subscribed to the event;
in order to comply with applicable laws and internal policies and procedures; or
for the administration and maintenance of databases storing your Personal Data.

Why we process your data

Where we intend to use your personal data, we rely on the following legal bases for processing:

Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, providing sales literature or quotations and where we respond to your requests and provide you with services in accordance with our terms and conditions or other applicable terms of business agreed with you or with your employing organisation.

Legitimate Interests: Where we consider use of your information as being (a) non detrimental to you. (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data which may include:

for our own direct marketing or continued communication;
the prevention of fraud;
our own internal administrative purposes;
personalisation of the service(s) we provide to you;
ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems;
reporting possible criminal acts or threats to public security to a competent authority

Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws and other regulatory provisions applicable to Next Gate Tech.

Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes where you or your employing organisation are not a client of Next Gate Tech or its associated companies. You may withdraw this consent at any time by contacting us.

How long do we keep your personal data?

We take every reasonable step to ensure that your Personal Data are only processed for the minimum length of time required, which is dependent on:

the purpose for which we are using it - we will need to keep the data for as long as is necessary for that purpose; and
our legal obligations – laws may set a minimum period for which we have to keep your Personal Data.

Who we share your data with

We do not share or sell your Personal Data with other individuals or organisations.

However, we may transfer your data to third party data processors where it is necessary in order to provide you with our services. Data processors supply services to us or perform services on our behalf and are legally bound to act on our sole instruction with regards to your data. We will only share data which is necessary for that company to perform those services, in accordance with the applicable law.

We may need to disclose your Personal data:

To the extent required by law or regulation, for example to comply with any legal obligation or to establish, exercise or defend the Company’s legal rights; and
If we sell any part of our business, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

International data transfers

Where we transfer your Personal Data to another country we ensure that it will be protected and transferred in a manner consistent with legal requirements. In relation to data transferred outside of the European Economic Area (the “EEA”), for example this may be done in one of the following ways:

European Commission’s adequacy decisions;
Our binding corporate rules;
Suitable standard contractual clauses; or
Other valid transfer mechanisms.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us at privacy@nextgatetech.com.

Your rights

Next Gate Tech would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access - you have the right to request the Company for copies of your Personal Data.

The right to rectification - you have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete information you believe is incomplete.

The right to erasure - you have the right to request that the Company erase your Personal Data, under certain conditions.

The right to restrict processing - you have the right to request that the Company restrict the processing of your Personal Data, under certain conditions.

The right to object to processing - you have the right to object to the Company's processing of your Personal Data, under certain conditions.

The right to data portability - you have the right to request that the Company transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@nextgatetech.com.

Cookies

A cookie is a small file that is placed on your device when you visit a website (including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy.

Questions

If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at: privacy@nextgatetech.com.

Ownership and delivery

This policy is owned and delivered by the management committee within Next Gate Tech.

Reviewing and updating

This Policy is maintained by the Head of Operations and owned and delivered by the Management Committee within Next Gate Tech.