Global privacy notice.
01Important information and who we are
Omnes and its affiliatesNote 1 (“we”, “us”, “our”, or “Omnes Group”) collect, use and share personal information when you use any service that they offer. This global privacy notice has been created to cover how we collect, use and disclose personal information and is relevant to our website visitors and users of our services. This global privacy notice describes the types of personal information we collect, the purposes for processing that personal information, the third parties we share your personal information with and the security measures we have implemented to keep your personal data secure. It also sets out the rights and choices of individuals and how to contact us about the information contained in this global privacy notice, wherever you are in the world.
Where any entity within the Omnes Group acts as a controller, the controller will be deemed to be the Omnes Group entity listed on the terms and conditions that you enter into when using an Omnes Group service.
This global privacy notice sets out some core content and, where applicable, can be read in conjunction with any supplemental privacy notices as required by country-specific law. This is where certain country-specific information, such as individuals’ rights, can be found. In the absence of any country-specific information, this global privacy notice will apply.
Our global privacy notice and any associated country-specific privacy notices will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure they remain appropriate to the changing global environment.
1 Omnes and its affiliates refers to the companies that are directly or indirectly owned or controlled by Omnes Holdings Ltd. ↑
02Data protection principles
The Omnes Group seeks to comply with all data protection laws that are applicable around the world. Where possible, we have adopted the core principles set out in the GDPR to inform how we collect and use your personal information. The principles are as follows:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
03Kinds of personal information we collect
Personal information or personal data means any information about a living individual from which that person can be identified, even without any linkage to their name. It does not include data where the identity of the individual has been completely and permanently removed (which is called anonymous or anonymised data). The types of personal information we collect include the following categories:
- Identity and profile
- Contact
- Financial
- Usage
- Transaction
- Marketing and communications
- Technical
Examples of these categories are set out in the table below in section 10.
04How is your personal information collected
We collect information from you where you fill in forms on our website or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our website, when you report a problem with our site or when you contact us to discuss any aspect of your account with us. When you visit our website, access our services, engage with our emails and online ads, we may collect information by automated means. For more information on how we collect your data, please refer to the Cookies Policy on our website.
We obtain most of the customer personal information shared with us directly through account applications or other submission forms, and from maintaining records of customer information provided in the course of our ongoing customer service. We may also obtain information from other sources to meet certain regulatory requirements.
On occasion, we will ask for other information voluntarily (for example, through market research, surveys or special financial promotion offers) to enable us to improve our service or consider the wider needs of our customers.
Information we receive from other sources
On occasion, we will collect your personal information indirectly and through a third party. Examples of this include our use of blockchain analytics services to perform KYT (know your transaction), as well as credit reference agencies to perform KYC (know your client), KYB (know your business), and AML (anti-money laundering) checks.
05How do we use your personal information
We will only use your personal information when applicable data protection law permits us to, including by identifying any necessary lawful bases for processing (i.e. a legally permissible reason for processing your personal information).
The table below contains the purposes for which we plan to use your personal information, the types of data applicable to this purpose and the applicable lawful basis for our processing activities:
| Purpose | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client | (a) Identity and profile (b) Contact | Performance of a contract with you |
| To process your transaction including (a) manage payments, fees and charges and (b) collect and recover money owed to us | (a) Identity and profile (b) Contact (c) Financial (d) Transaction (e) Marketing and communications | (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, including (a) notifying you about changes to our terms or privacy policy and (b) asking you to leave a review or take a survey | (a) Identity and profile (b) Contact (c) 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 study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity and profile (b) Contact (c) Usage (d) 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 (troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting) | (a) Identity and profile (b) Contact (c) Technical | (a) Necessary for our legitimate interests (running our business, IT services, network security, fraud prevention, business reorganisation) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements and measure their effectiveness | (a) Identity and profile (b) Contact (c) Usage (d) Marketing and communications (e) Technical | Necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business and inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define customer types, keep our website updated, develop our business and inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may interest you | (a) Identity and profile (b) Contact (c) Technical (d) Usage | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| If we are under a duty to disclose or share your personal information to comply with any legal obligation, enforce our terms, or protect rights, property, or safety (including fraud protection and credit risk reduction) | (a) Identity and profile (b) Contact (c) Financial (d) Transaction (e) Marketing and communications | Necessary to comply with a legal obligation |
| In the event of M&A activity (reorganisation, selling/buying any business or assets, joint venture, assignment, transfer or other disposition) | (a) Identity and profile (b) Transaction | Necessary for our legitimate interests (where it is necessary for the sale of the business or shares to disclose the data to a potential buyer) |
06Disclosures of personal information
We share your personal information with our trusted third parties as part of the operation of our global business. Your personal data will be shared with the following categories of recipients:
- other companies within the Omnes Group of companies who provide financial and other services;
- service providers and specialist advisers who have been contracted to provide us with administrative, financial, insurance or other similar or related services;
- introducing brokers with whom we have a mutual relationship;
- credit providers;
- blockchain analytics services providers;
- courts, tribunals and regulatory and government tax authorities as agreed and authorised by law;
- reference and credit reference agencies. This includes exchanging information with other companies and organisations for the purposes of money laundering regulations, financial crime, fraud protection and mitigation of credit risk;
- anyone authorised by you to act on your behalf, as specified by you or by law through power of attorney;
- advertisers and advertising networks that require data to select and serve relevant adverts to you and others (we do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information);
- analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
07Security
Protecting your personal information and your privacy is very important to us. At a global level, we have set high standards for data security. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised manner. In addition, we limit access to your personal information to those employees and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
08International transfers
The Omnes Group is an international business that has operations and service providers around the world.
We may transfer your personal information outside the jurisdiction in which the relevant controller (pursuant to this global privacy notice) is incorporated (“Jurisdiction”), including to processors engaged on our behalf. Where we transfer your information outside of the Jurisdiction, we will ensure that the transfer is lawful and that there are appropriate security and contractual arrangements in place to safeguard such transfers.
If we transfer your personal data to another country that doesn’t offer a standard of data protection equivalent to that of the Jurisdiction from which your personal data is transferred, we will ensure that your personal data is sufficiently protected through mechanisms such as (where applicable), (i) approved Standard Contractual Clauses; (ii) the UK Approved Addendum; (iii) Binding Corporate Rules; (iv) standard data protection clauses, certification or an approved code of conduct adopted by a supervisory authority within the Jurisdiction; or (v) a contractual framework deemed to provide an adequate level of protection for personal data.
To the extent applicable, please see any country-specific notices for additional details in relation to our international transfers and our appropriate safeguards in place.
09How long we keep your personal information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
To receive additional details around our retention periods, please contact us using the details in section 12 below.
10Types of personal information: examples
We may collect, use, store, transfer and otherwise process different kinds of personal information about you, which we have grouped together as follows:
| Type of personal information | Definition |
|---|---|
| Identity and profile | Identity Data includes name, username or similar identifier, online account profile information, marital status, title, date of birth and gender. |
| Contact | Contact Data includes billing address, delivery address, location, country, email address and telephone numbers. |
| Financial | Financial Data includes bank account and payment card details. |
| Usage | Usage Data includes information about how you use our websites, mobile applications, Wi-Fi and similar electronic services. |
| Transaction | Transaction Data includes details about payments to and from you and other payment details of products/services you have purchased from us. |
| Marketing and communications | Marketing and Communications Data includes your marketing and communication preferences. |
| Technical | Technical Data includes information collected when you access our websites or mobile applications, your IP address, login data, browser type and version, time zone setting and location and country, browser plug-in types and versions, operating system and platform, and other technology on the devices you use. |
11Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These may include:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- rights in relation to automated decision making and profiling.
You can exercise your rights by contacting us using the details set out in section 12 below.
If you have concerns about how we deal with your data, you have a right to complain to your local data protection authority, or to the data protection regulator in the country where you live or work.
12How to contact us
If you have questions or comments about our privacy practices, or if you would like help exercising your privacy rights, you can contact us via one of the methods set out below:
13Changes to our privacy notices
Any changes we make to our global privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our global privacy notice.