Last updated


This privacy policy was last updated on 15th December 2019


Privacy Policy (GDPR Regulations)


In this section, we will be explaining our privacy policy relating to citizens located within the European Union and/or the United Kingdom.

This privacy policy is based on the rights stated on the ICO website

Information collected


We may collect information including but not limited to:

- ID documents
- Name, address, mobile number
- Proof of Address
- Other (in this event we will notify you with what we require)

We usually will only collect data in which you already have access to however this may not always be the case. In situations where we collect data which you do not have access to, we will aim to notify you as soon as possible (within 30 days). Where we are unable to provide you with notice within a 30 day period, we will notify you with our reasoning. We are not required to inform you of this privacy information where information we collect is already available to you however, we do so for good practice.

We retain your data for 13 months after your last transaction with us. An example of this, if you transacted with us on the 21st March, and you then transacted with us on the 1st April, then the 13 month period would start from the last transaction you did with us (which would mean it would be held for 13 months from 1st April). The 13 month holding period gets reset every time you perform a new transaction with us.

We store the information and will only share it with the following people (where necessary):

• Police (in the event a criminal investigation is launched against you)
• Law Enforcement (where information is legally required to be handed over)
• Fraud Investigators (where a dispute/case is opened relating to you, we can provide your information to the individual(s) handling the dispute/case).
• Other (wherever there is a legal obligation to do so. If we are required to share your information with anyone who does not have a legal need for it, we will aim to contact you first prior to sharing the information. We will NOT share your information with anyone who does not have a legal need for it UNLESS we have your expressed permission to do so.)

Access of Information


You have the right to make a subject access request (SAR) to obtain a copy of personal data that we hold on you as well as other supplementary information (where supplementary information is necessary).

We aim to deal with all SAR's within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle a Subject Access Request, we will explain our reasoning for the SAR taking longer.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to releasing the information we hold on you. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

In particular circumstances we may be reject your Subject Access Request. Your Subject Access Request will only be declined in the event that:

▶ The request is manifestly unfounded;
▶ The request is excessive;
▶ There is an exemption.

In the event we decline a SAR, we will present our reasons for the refusal of upholding the Subject Access Request.

Right to rectification


If you believe that some of the data we hold on you is inaccurate or incorrect, you have the right to have that inaccurate or incorrect data amended by submitting a rectification request.

We aim to deal with all rectification requests within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle a rectification request, we will explain our reasoning for the rectification request taking longer.

In the event that we are unable to correct inaccurate of incomplete data at the time of receiving the rectification request, we will make a note to correct the inaccurate or incomplete data wherever necessary. This may mean correcting the incorrect or incomplete data at a later time and/or date.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to rectifying the information we hold on you. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

In particular circumstances, we may reject your rectification request. Your rectification request will only be declined in the event that:

➤ We are confident that the information you are requesting for rectification is accurate and/or correct and thus, the data is not required to be amended;
➤ The request is manifestly unfounded;
➤ The request is excessive;
➤ There is an exemption.

In the event that we decline a rectification request, we will present you with the reasoning as to why we are not upholding the rectification request.

Right to Erasure


You have the right to request to delete any data that we hold on you. This is also known as the right to be forgotten.

This right is not absolute, and we are not always required to delete information on request. This right only applies in particular circumstances.

We will only delete data that we hold on you if one or more of the following conditions apply:

➡ It is no longer necessary for the purpose in which we originally collected or processed it for;
➡ We collected the information with your consent, and you wish to withdraw your consent;
➡ We are relying on legitimate interests as the basis of processing your personal data, you object to the processing of your data, and there is no overriding legitimate interest to continue with the processing of your personal data;
➡ We are processing personal data for direct marketing purposes, and you object to that processing;
➡ We have processed your personal data unlawfully;
➡ We are required to erase your personal data to comply with a legal obligation;
➡ We have processed personal data to offer information society services to a child.

Personal Information relating to a child

We are not looking to process any personal information relating to individuals under the age of 16. If you are looking to use our services and you are under the age of 16, we advise you to find someone else. By providing us with your personal data, you are acknowledging that you are age 16 or above.

Right to erasure (continued)

We are NOT required to erase your personal information if one or more of the following conditions apply:

➜ To exercise the right of freedom of expression and information;
➜ To comply with a legal obligation;
➜ For the performance of a task carried out in the public interest or in the exercise of official authority;
➜ For archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing;
➜ For the establishment, exercise or defence of legal claims.

There are also two other circumstances where the right of erasure does not apply in relations to special category data, and these are:

➜ If the processing is necessary for public health purposes in the public interest (eg protecting against serious cross-border threats to health, or ensuring high standards of quality and safety of health care and of medicinal products or medical devices);
➜ If the processing is necessary for the purposes of preventative or occupational medicine (e.g. where the processing is necessary for the working capacity of an employee; for medical diagnosis; for the provision of health or social care; or for the management of health or social care systems or services). This only applies where the data is being processed by or under the responsibility of a professional subject to a legal obligation of professional secrecy (e.g. a health professional).

We aim to deal with all right to erasure requests within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle a right to erasure request, we will explain our reasoning for the right to erasure request taking longer.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to complying with your request for erasure. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

In particular circumstances, we may reject your right to erasure request. Your right to erasure request will only be declined in the event that:

➜ There is an exemption that prevents us from erasing your data;
➜ Your data falls under one or more conditions which requires us to retain it and therefore we are unable to erase your personal data;
➜ The request is manifestly unfounded;
➜ The request is excessive.

In the event that we decline a right to erasure request, we will present you with the reasoning as to why we are not upholding the right to erasure request.

Consent and retaining personal data

This section explains more in-depth about your personal data.

By providing us with your personal data (including but not limited to; identification documents, name, address, telephone number and any other information we can use to personally identify you, you are consenting to us storing it.

You understand that consent is not our main lawful basis of storing your personal data, and our acknowledge that our main lawful basis of storing your personal data is to comply with legal obligations.

Your information will only be used in the following situations:

- For fraud prevention (this is our MAIN legal obligation);
- In the event that a case and/or dispute is raised by you in relation to us;
- Where we are legally required to provide your personal data to law enforcement.
- Where we have to take legal action in order to obtain funds which you legally owe us.
- Any other cases where your information is legally required to be handed over.

You can find information pertaining who we share the information with within the 'Information Collected' section towards the top of this privacy policy.

Right to restrict processing


You have the right to request the restriction or suppression of your personal data.

This right is not absolute, and we are not always required to restrict or suppress the processing of your data on request. This right only applies in particular circumstances.

We are only required to restrict processing of your personal data if one or more of the following conditions apply:

➠ You contest the accuracy of the personal data in which we hold on you, and we are verifying the accuracy of the data;
➠ The data has been unlawfully processed, and you request us to restrict the processing of the data instead of erasing it;
➠ We no longer need the personal data however, you require us to keep your personal data in order to establish, defend and/or exercise a legal claim;
➠ You have objected to us processing your personal data, and we are considering whether our legitimate grounds override those of yours.

We aim to deal with all right to restriction requests within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle a right to restriction request, we will explain our reasoning for the right to restriction request taking longer.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to complying with your right to restriction request. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

In particular circumstances, we may reject your right to restriction request. Your right to restriction request will only be declined in the event that:

➠ You have objected to us processing your personal data and we deem that our legitimate grounds override those of yours;
➠ The request is manifestly unfounded;
➠ The request is excessive;
➠ There is an exemption.

In the event that we decline a right to restriction request, we will present you with the reasoning as to why we are not upholding the right to restriction request.

Right to data portability


The right of data portability allows you to obtain and reuse personal data for your own purposes across different services.

This right only applies to information in which you have provided to us.

The right of data portability only applies when the following conditions apply:

➩ We are processing your personal data on a consent basis or, for the performance of a contract; and
➩ We are carrying out the processing by automated means.

The right of data portability allows you to:

➩ Receive a copy of your personal data; and/or
➩ Have your personal data transmitted from one controller to another controller.

We can achieve this in one of two ways. We will either:

➩ Directly transmit the requested data to you; or
➩ Provide you access with an automated tool that allows you to extract the requested data yourself.

We reserve the right to choose the method of data portability wherever the right of data portability applies.

We aim to deal with all data portability requests within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle a data portability request, we will explain our reasoning for the data portability request taking longer.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to complying with your data portability request. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

In particular circumstances, we may reject your right to data portability request. Your right to data portability request will only be declined in the event that:

➩ The right to data portability does not apply to you;
➩ The request is manifestly unfounded;
➩ The request is excessive;
➩ There is an exemption.

In the event that we decline a right to data portability request, we will present you with the reasoning as to why we are not upholding the right to data portability request.

Right to object


The right to object allows you to object to the processing of your personal data.

The right to object only applies in certain circumstances.

The right to object applies when one or more of the following conditions apply:

➨ We are processing your personal data for direct marketing purposes;
➨ We are processing your personal data for a task carried out in the public interest;
➨ We are processing your personal data for the exercise of official authority vested in us;
➨ We are processing your personal data for our legitimate interests.

The right to object to us handling your personal data is not an absolute right.

We can refuse to comply with your objection if one or more of the following conditions apply:

➨ There is an exemption;
➨ The request is excessive;
➨ The request is manifestly unfounded;
➨ We can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms;
➨ The processing is for the establishment, exercise or defence of legal claims.

In the event that we decline a right to object request, we will present you with the reasoning as to why we are not upholding the right to object request.

We aim to deal with all objection requests within 1 month (30 days) of receiving them. If we take longer than 1 month (30 days) to handle an objection request, we will explain our reasoning for the objection request taking longer.

In certain cirumstances we may charge an administration fee and/or request an identification document (for example a drivers license, passport or other government issued identification document) to us prior to complying with your objection request. If we do request an identification document and/or charge a fee, the 1 month (30 day) timeframe will begin from when we receive the identification document and/or the fee.

Rights related to automated decision making including profiling


This section explains your rights when it comes to:

➱ Automated individual decision-making (making a decision solely by automated means without any human involvement); and
➱ Profiling (automated processing of personal data to evaluate certain things about you). Profiling can be part of an automated decision-making process.

In the event we are involved in Automated individual decision making and/or Profiling, we will ensure:

➱ You are provided information about the processing;
➱ You are provided with simple ways to request human intervention or challenge a decision;
➱ We will carry out regular checks to ensure our systems are working as intended.

Furthermore, we will only carry out these kind of activities (decision-making and profiling) when one or more of the following conditions apply:

➱ It is necessary for the entry into or performance into a contract;
➱ We are authorised by Union or Member state law applicable to us;
➱ It is based on your explicit consent.

Although our business is not based around automated decision making and profiling, we have included it in our privacy policy as good practice. Whenever we use automated decision-making and profiling, we will notify you and get your consent prior.

Contact


You can contact us through any of the mediums below:


- Discord: Management#5555 (case sensitive)

- Through post at the following address:

   Radiant Trading Global LTD
   Company number: 12138786
   Kemp House
   160 City Road
   London
   EC1V 2NX

- Email: contact@radiant-global.com

Complaints


If you have any complaints regarding the way we have handled your personal data, you have the right to submit any complaints to the Information Commissioner's Office.

Your responsibilities

This section explains your responsibilities

We reserve the right to modify this privacy policy at any time wherever we feel modification of this privacy policy is necessary.

You hold a certain level of responsibility to ensure that you read this privacy policy prior to each transaction you might make with us.

It is important to read this privacy policy prior to conducting a transaction with us so you know your rights regarding how your personal data is processed.