At Silicon Signals we take privacy seriously and we are committed to protecting it.
a. how we collect and look after your personal data when you visit our website;
b. how your personal data will be processed by us;
c. when and how it may be disclosed to others;
d. how it is kept secure; and
e. your privacy rights.
This policy changes from time to time, so please check this page occasionally to ensure that you’re happy with any changes.
We collect your personal data to provide you with our services as specified in our Customer Terms and Conditions and other documents regulating our business relationship with you and published at www.torchmarkets.com/dataprotectionpolicy .
We only use personal information as appropriate to provide you with a high quality of service and security. We may use the personal data collected from you to verify your identity and contact information and to establish the business relationship with you. We may also use this information to establish and set up your trading account, issue an account number and a secure password, maintain your account activity, and contact you with account information.
We use your personal data to receive or send payments to or from you. In this case, we may share your personal data with external payment provider, which you use to process the payment to or from us, for example: your bank, corresponding banking institution or payment services provider. This information helps us improve our services, comply with our statutory obligations and inform you about new products, services or promotions that may be of interest to you.
This website is not intended for children and we do not knowingly collect data relating to children.
3. Data Controller
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your use of our website and services.
5. Personal Data We Collect About You
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, which we have grouped together as follows:
(i) information that you provide by filling in forms on our website, in emails, by calls, in our live chat, or support centre;
(ii) up-to-date data about yourself and your identity, by registering your personal details to use our services;
(iii) data you provide to us in the applications we ask you to fill in on our website; and
(iv) details of your visits to our website, details of your emails, calls and requests sent through the live chat, support centre from, including, but not limited to: traffic data, location data, weblogs and other communication data, the resources that you access, devices and services you use to contact
Categories of personal data
The personal data that we collect, process and control from our customers, in order to provide our services, include:
(i) Identity Data: including first name, last name, title and username;
(ii) Contact Data: including email address and phone number;
(iii) Geographic Data: including your country of residence;
(iv) Transaction Data: including trading data such as orders and their execution results;
(v) Technical Data: including the IP addresses used to access our website and services, your activity logs in our systems, browser type, operating system and platform and other technology you use on your device;
(vi) Usage Data: including information about how you use our website, products and services;
(vii) Profile Data: including your username and password, purchases and /or orders made by you on our Website, your interests, preferences, feedback and survey responses; and
(viii) Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
6. If you fail to provide personal data
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 with you or are trying to enter into with you (for example, to provide you with products and/ 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.
7. How is your personal data collected?
We use different methods to collect data from and about you including through:
(i). Direct interactions. You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by phone, email or otherwise.
This includes personal data you provide when you:
Please see our Cookies Policy for further details.
8. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(i).Where we need to perform the contract we are about to enter into or have entered into with you.
(ii).Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(iii). Where we need to comply with legal obligations.
Generally, we do not rely on consent as a legal basis for processing your personal data . You have the right to withdraw consent to any marketing communications from us at any time by contacting us.
9. Purposes for which we will use your personal data
This is where a processing activity is in the interests of successfully managing to enable us to give you the best products and services and most secure experience; for example to analyse and improve our marketing strategy.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract
This is where we process your data in order to perform our obligations in a contract, to which you are a party or in order to take steps at your request, before entering into such a contract; for example, we supply products and services to you, and you pay for them.
Comply with a legal obligation
This is where processing your personal data is necessary for compliance with a legal or regulatory obligation we are subject to; for example, assisting a public authority with a criminal investigation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer (including by automated means)
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
10. Third Parties
Third parties we may be required to share your data with
We may, from time to time, be required to share your data with the following third parties:
(i). Partners, vendors, service providers
In order to ensure the functionality of our systems, software maintenance, resolution of bugs, migrations of data to new software versions, some of your personal data may be disclosed.
(ii). Law enforcement, Government and Regulatory authorities
Where we are required to disclose information and personal data in order to comply with legal and regulatory obligations in all the countries in which we operate.
(iii) Client service businesses
In order to help us improve our services to you, we may engage client service businesses to help us carry out data collection activities, to help better understand and identify customer’s needs
(iv). Trading data depositories
In accordance with applicable legislation we are required to upload your trading data (including trading orders and / or trading positions) as well as your Identity Data, to trading data depositories.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third party websites
We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of personal data provided by you or collected by those sites.
We strive to provide you with choices regarding the use of your personal data for marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have not opted out of receiving that marketing.
We do not share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us through your purchase of products and services, or any other actions you complete on our website.
12. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
13. International transfers
We may transfer personal data from the European Economic Area (“EEA”) and United Kingdom to countries located outside the EEA in which our servers are located, in connection with the provision of services to you and operation of our online website and facilities.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(i) countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
(ii) for transfers to the US, we may transfer data where the receiving entity is part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US; and
(iii) for transfers to all other countries, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; standard contractual clauses for the transfer of personal data to third countries
14. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
15. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. For example, being a financial services provider we shall keep some of your personal data to comply with FATF recommendations, Money Laundering Regulations 2017.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
What happens when I de-activate my account?
Following the de-activation of your account and any de-subscription from our services, we will retain your data for 30 days, following which it will be securely deleted from our servers and records.
Where will my data be stored?
The primary storage location is in the European Union and United Kingdom.
16. Your legal rights
Under data protection laws you have the following rights, in relation to your personal data.
(i) Request access to your personal data.
This is commonly known as a “data subject access request”.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(ii) Request correction of your personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(iii) Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(iv) Object to processing of your personal data.
This right can be exercised where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(v) Request restriction of processing your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(vi) Right not to be subject to a decision based solely on automated processing (including profiling)
We do not carry out any decisions based solely on automated processing.
(vii) Request transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(viii) Right to withdraw consent at any time.
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
111, Baker Street,
W1U 6SG London
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance