First Derivatives PLC and its affiliates (“FD”) respects your privacy and are committed to protecting your personal data. This privacy notice (“Notice”) will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you. We recommend that you read this Notice in full to ensure that you have a clear understanding of the data that we collect or receive and how we use that data.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how FD collects or receives and processes your personal data through your use of;
- our websites, including any data you may provide through the websites when you sign up to our newsletters, webinars and events or purchase a product or service and
- by corresponding with us, either through networking events or email/phone interaction.
This website is not intended for children and we do not knowingly collect data relating to children.
FD is a global technology provider with more than 20 years of experience working with some of the world’s largest finance, technology, automotive, utility, manufacturing and energy institutions. The Group’s Kx technology, incorporating the kdb+ time-series database, is a leader in high-performance, in-memory computing, streaming analytics and operational intelligence. Kx delivers the best possible performance and flexibility for high-volume, data-intensive analytics and applications across multiple industries. FD operates from 15 offices across Europe, North America and Asia Pacific, including its headquarters in Newry, and employs more than 2,400 people worldwide.
THE 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:
- Business contact information – (e.g. your name, mailing address, telephone number and/or email address)
- Usage Data – includes information about how you use our website, products and services.
- Marketing and Communications Data – includes your preferences in receiving marketing from us 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, 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.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your business contact information by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you purchase a product or service, sign up to or attend our events or webinars, face to face through networking, download content or software from our website or give us feedback/contact us.
- Third parties or publicly available sources. We may receive personal data about you in the form of business contact data from various third-party providers and public sources.
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:
- Where we need to perform the contract that we are about to enter or have entered into with you.
- 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.
- Where we need to comply with a legal obligation.
- Where you have consented to being contacted by us.
LEGAL BASIS FOR PROCESSING THE PERSONAL DATA
FD relies on several different legal grounds for processing personal data including performance of a contract, consent and legitimate interest, depending on the circumstances surrounding the processing.
FD may process personal data pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. For example, we may process Personal data pursuant to legitimate business purposes to respond to your inquiries and to fulfil your requests or to send you marketing information and offers.
We may also from time to time relying on consent to process your data for marketing purposes particularly where this is required by law. You have the right to withdraw consent to marketing at any time by contacting us. Please see our section on “opting out” below.
If you are an individual from the EEA, our legal basis for collecting and using personal data will depend on the personal Data concerned and the specific context in which we collect it. However, we normally rely on our legitimate interests to collect personal data from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the ‘contact us’ section below.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We may use and process your information based on the legal grounds and for the legitimate business purposes outlined in this Notice. We have set out below, a description of all the ways we plan to use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Personal data may be used for the following purposes;
- Marketing purposes – FD may use personal data to send you various marketing regarding FD products and services via email or phone.
- To make content and webinars available to you – FD may process personal data provided by you to make available requested content or webinars
- To provide you with a service/product – personal data may be processed to provide you with FD products or services which may have been download from the FD website or purchased via other means.
- To enable you to attend an event – where you have provided your information to attend an FD event or and affiliated event, FD may process this data to communicate further information to you which may be of interest
- To make suggestions and recommendations to you about goods or services that may be of interest to you – FD may process your personal data to make available information it deems to be of interest to you regarding FD products and services
We may use your personal data along with other information 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 requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.
OPTING OUT AND CHANGING YOUR MARKETING PREFERENCES
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase and for which we might need to process for other purposes and on other legal grounds.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share or disclose your personal data for the purposes set out above. Examples include;
- Third Parties
– FD may from time to time share your personal data with third party partners who are assisting in the organisation and management of events and webinars.
– FD may share your information with its affiliates (meaning any subsidiary, parent company or company under common control of First Derivatives PLC). Our affiliates will use your information only for the purposes described in this Notice.
– FD may also use third party systems and platforms to facilitate its marketing activities.
– FD may choose to sell, transfer or merge parts of its business or assets. Alternatively, FD may seek to acquire other businesses or merge with them. If a change happens to the FD business, then the new owners may use your personal data in the same way as set out in this Notice.
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-party service providers 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.
Personal data collected or received for the purposes outlined above, is transferred to and stored in FD servers in the United States of America. We will protect your personal data in accordance with this Notice wherever it is processed.
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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts known as the EU Model Clauses which have been approved by the European Commission and give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 instruction and 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected, received or obtained it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to;
- Request access to or ask that we change, update, or delete your personal data at any time.
- Withdraw your consent at any time, where FD are processing your data on the legal ground of consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- Opt out of receiving marketing communications from us/
If you are a resident of the European Economic Area (EEA), you may also have the right to:
- Object to processing of your personal data, restrict processing of your personal data or request portability of your personal data.
- Complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
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.
UPDATES TO THE PRIVACY NOTICE
We keep our Notice under regular review. This version was last updated on 5th June 2020. If we make any material changes, we will notify you by means of a notification on www.firstderivatives.com website prior to the change becoming effective.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
If you have any questions about this privacy notice or our privacy practices, please contact us:
FAO: Data Privacy team
Brian Conlon House, 3 Canal Quay, Newry, BT35 6BP, Northern Ireland
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.