Privacy Notice

TP ICAP (“we”, “us”, “our”) is committed to safeguarding personal information of website visitors such as names, contact details and ID data ("Personal Information"). To the extent that any Personal Information is collected, it is held securely and in line with "Data Protection Legislation" meaning the General Data Protection Regulation (EU) 2016/679 and the UK Data Protection Act 2018 and TP ICAP is the data controller in respect of any personal information collected from website visitors or otherwise online or by digital means.

This Privacy Notice sets out how and why personal information may be collected by TP ICAP from website visitors and provides other information as required by law including how we respect individual rights, and how TP ICAP’s Cookie Notice applies to any person visiting any TP ICAP websites.

Personal Information we may collect about you includes:
•    Identification data, full name, title, gender, marital status, date of birth, passport number, driving licence number, national identification number, signature, address etc.

Special category data (formerly sensitive personal data) 
•    Special Category Data is information concerning an individual's: (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, (vii) commission or alleged commission of any offence or any proceedings for any offence committed alleged to have been committed by him/her, the disposal of such proceedings, or the sentence of any court in such proceedings. Where we receive special category data, TP ICAP only retains the information that is  strictly necessary to comply with our legal obligations.

Personal Information from other sources 
We may receive information from third parties that collect Personal Information from you and pass it  on to us. For example: (i) in connection with services that we provide to our clients; and (ii) we may receive information from past employers and others concerning your employment history where you apply for a job with us. Where this is the case the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Notice and obtaining any relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used. However, once we are holding it, we will only handle any person's Personal Information in accordance with this Policy.

When you engage with us (e.g. sending us emails, contacting us via telephone, or visiting or making and enquiry through the Website) you may provide Personal Information about yourself including your name and contact details e.g. your address, email address, and telephone number. If you are using our services, you may also provide us with your financial information and various other necessary Personal Information. Where you make use of the Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of compliance with applicable legislation and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of the Website and services and support our staff and clients). In every case we will only collect your Personal Information for lawful and transparent means, with your explicit consent where required and where no other legal grounds for processing exists.

We may use certain information collected from your interactions with our Website—including device identifiers, IP address, browsing behaviour, and engagement patterns - to generate insights using artificial intelligence (“AI”). We use these insights to understand how visitors engage with our Website and digital content, to tailor and improve our services, and to provide a more relevant user experience. This processing may include automated analysis or limited profiling to understand preferences, interests, and usage trends. We do not make decisions that produce legal or similarly significant effects for you solely on the basis of automated decision‑making.

Where required by applicable law, we will obtain your consent before using cookies or similar technologies that enable this type of analysis. You have the right to object at any time to our use of your Personal Information for profiling for direct marketing or service‑enhancement purposes. To exercise your rights, please contact us using the details set out below or adjust your cookie preferences in our cookie management tool.

Upon request we will clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

We will use Personal Information only in ways that are compatible with the purposes for which it was collected, authorised by this Privacy Notice, or authorised by you. We will take reasonable steps to ensure that Personal Information is relevant to its intended use, and is accurate, complete, and current (as provided by you). We depend on you to update or correct your Personal Data whenever necessary.

To comply with legal and regulatory obligations including recording employee calls made on employees' landlines and mobile telephone lines.

For recruitment purposes 
If you apply for a job with us, we may collect personal information from you and where relevant, from third parties

Where you provide Personal Information on behalf of another individual you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Notice so they can see how we will process their Personal Information.

Why we need your personal information:  
We use your Personal Information:
(a) to provide you with our services on an ongoing basis, in accordance with our contract, 
(b) to improve our Website and services, for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns 
(c) to comply with our own legal and regulatory obligations, including in relation to financial promotion, applicable anti-money laundering and counter terrorist financial legislation 
(d) for our internal business processes, including providing support to our staff  
(e) where relevant, process your application for employment 
(f) to provide you with news, general information about other goods, services and events which we offer that are similar to those that we have provided to you unless you have opted not to receive such information 
(g) to develop and display content and advertising (and work with third-party vendors who do so, tailored to your interests and/or location and to measure its effectiveness and 
(h) to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our service users is among the assets transferred.

Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your Personal Information in connection with the provision of the services, such as your name, business contact details and other Personal Information. We will only process such Personal Information in connection with the provision of the services (such as using your contact details to discuss the services) and in accordance with this Policy. In addition, where necessary, we may also share your Personal Information with third parties in order to provide our services.

If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting GlobalDataPrivacy@tpicap.com.

How we use your personal Information
Where it is necessary for the performance of our contract with you, or for our internal business processes, we may share your Personal Information with certain third parties, professional advisors, service providers, regulatory bodies, auditors, technology providers, and any duly authorised agents or related, associated, or affiliated companies of the foregoing for the same purposes.

By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We ask all third parties to treat your Personal Information securely and in accordance with this Notice and will take reasonable steps to enforce this.

In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering or anti-terrorist financing obligations), carry out an internal investigation, enforce our Terms and Conditions on our Website and any other agreement, or protect the rights, property, or safety, of our companies and our clients, directors, employees, or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention. They in turn may exchange information (including Personal Information and financial information) with foreign tax authorities.

In exceptional circumstances, if we are sold or merged with another company we may disclose your information to a potential buyer, including your Personal Information and other information concerning your relationship with us, so that they can continue to provide the services you have requested.

Security Measures
We only retain your Personal Information for as long as we have a legitimate business interest to do and in line with the Data Protection Legislation.

Where you have chosen a password which allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information when transmitted via the Website; any transmission is therefore at your own risk.

Where we become aware that your Personal Information has been compromised by a data breach (as defined by the Data Protection Legislation) we will make reasonable efforts to notify you in a timely manner.

Data Transfers
Any Personal Information provided to us may be transferred to and stored on third parties’ servers and we take reasonable steps to ensure these procedures comply with relevant laws. We take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction, and damage.

If you are located in the European Economic Area (“EEA”) or the UK: Some of the non-EEA countries are recognised by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA or UK to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data.

Your Rights 
a.    To request a copy of all the information that we hold about you;
b.    To request amendments or corrections so that your records are accurate and up to date; 
c.    To request that your information is deleted;
d.    To request erasure of your Personal Information;
e.    To request that your information is forwarded on to a 3rd party (“right of data portability”); and
f.    To withdraw any consent that you have provided as the legal basis for our processing of your Personal Information.

You may exercise your rights of access, rectification, cancellation and opposition by contacting us: 

Contact Us

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Privacy Notice.

Categories of Personal Information We Collect

We may collect certain categories and specific pieces of information about individuals that are considered "Personal Information" in California ("CA Personal Information"). Specifically, we may collect the following categories of CA Personal Information:

•    Identifiers, such as name, date of birth, address, gender, and marital status; 
•    Commercial information, such as financial information, and 
•    Internet or other electronic network activity information, such as IP address, device identifiers, browsing behaviour, and web browser.

CA Sensitive Personal Information

Certain CA Personal Information that we collect about you may be considered sensitive personal information within the meaning of California Privacy Law, including passport number, driver’s license number, and national identification number . We only use and disclose sensitive personal information as necessary in connection with the performance of services, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.

Sources of CA Personal Information
We may collect this CA Personal Information from you and other third parties as described above.

Purposes of Collection
We collect and use CA Personal Information for the business and commercial  purposes described in the “How we use your personal Information” section above.

We may use automated processes to understand your preferences and interests.  

Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of CA Personal Information for business or commercial purposes to the categories of recipients listed below:

•    We disclose Identifiers with Google (Google Analytics) and Microsoft (Microsoft Clarity)
•    We do not disclose Commercial Information.
•    We disclose Internet and Other Electronic Information with Google (Google Analytics) and Microsoft (Microsoft Clarity

We may also need to disclose any of the above categories of information pursuant to a legal process or as a result of a merger or acquisition as described in this Privacy Notice. As stated above under “Security Measures”, we typically retain your CA Personal Information for as long as we have a legitimate business interest to do so, unless a longer retention period is required or permitted by law.

Some of our disclosures of CA Personal Information may be considered a “sale” or “share” as those terms are defined under California Privacy Law. Under California Privacy Law a “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioural advertising.

Your Rights under California Law

Subject to certain exceptions detailed in California Law and other applicable laws and regulations, as a California resident, you have the right to: 
(i) request to know/access your CA Personal Information, including the specific pieces and the categories of CA Personal Information we have collected or shared about you and the categories of sources from which we have collected the CA Personal Information; 
(ii) request deletion of your CA Personal Information; 
(iii) receive information about the CA Personal Information about you that we have "sold" to (as such term is defined under California Law) or “shared” with  third parties within the past 12 months, including the categories of third parties; and 
(iv) request correction of your CA Personal Information; and 
(iv) opt-out of the “Sale” or “sharing” of your CA Personal Information, as such terms are defined under California Privacy Law.

If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the CA Personal Information collected or shared with third parties, please contact us Globaldataprivacy@tpicap.com

a) Data Controller

TP ICAP Group plc, 135 Bishopsgate, London EC2M 3TP, with ICO no. ZA476173 is the data controller in respect of any personal information collected directly from all website visitors

b) Data Protection

Further Data Protection information can be sought via GlobalDataPrivacy@TPICAP.com.
Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA) or the UK, please contact your local data protection authority in the EEA or UK as applicable.