PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE SITE
Your rights to privacy are important to us.
We will only use the information that we collect about you lawfully and in
accordance with the Data Protection Act 2018 and the new General Data Protection
Regulation which the Act implements.
We have therefore put in place appropriate technical and organisational measures
to protect against unauthorised or unlawful processing of your personal
information and against accidental loss or destruction of, or damage to it.
- By using our site you accept these terms
Your access to and use of this website is subject to the terms of this policy, our
online Terms of Business and any other legal notices and statements contained on
this website. By using this website, you agree to be subject to the following terms.
If you do not agree to these terms, you must not use our site or open an account
with us. We recommend that you print a copy of these terms for future reference.
Reflex Trading takes your privacy very seriously and Reflex Trading will comply with the obligations
imposed on us by the applicable Data Protection legislation, including the UK Data
Protection Act 1998, the General Data Protection Regulation ((EU) 2016/679) (GDPR) and
any national implementing laws, regulations and secondary legislation, as amended or
updated from time to time, in the UK and any successor legislation to the GDPR or the
Data Protection Act 1998 (the Data Protection Legislation).
Reflex Trading is a Trading Name of Freyden Limited. Freyden Limited is a limited liability company registered in England and Wales with
its registered office 110 Carlton Avenue, Wembley, Middlesex HA9 8LU, United Kingdom. Company Number 11757447.
2.1. We shall use personal information provided by you in accordance with the provisions
of our Terms of Business and Customer Agreements and in accordance with this
2.2. Your use of our website constitutes acceptance of the terms of this policy.
technology and any changes to our operational processes and any amendments to
this policy will be incorporated in an updated version. Your subsequent use of the
website constitutes acceptance of those changes. Any information we hold will be
- Use of Personal Information
3.1. Reflex Trading needs to collect certain personal information to be able to offer its range of
financial products and services to its customers.
3.2. We will collect and maintain most personal information from customer use of this
website. This may be through the use of the application and other types of forms and
through active use of the customer trading account. The type of information may
include (but is not limited to) your name, address, date of birth, contact details,
employment and income, transaction history, areas of the website used and visited
and links to and from third party websites. Periodically we may ask you to voluntarily provide us with information for our marketing or survey purposes.
3.3. In accordance with the terms of your Data Protection Notice and Consent to our
use of your Personal Data:
3.3.1. to audit the usage of our website including:
3.3.2 to administer our website for internal operations, including
troubleshooting, data analysis, testing, research, statistical and survey
3.3.3 to improve our site to ensure that content is presented in the most
effective manner for you and for your computer;
3.3.4. as part of our efforts to keep our site safe and secure;
3.3.5 for training purposes;
3.3.6 to satisfy and meet our legal and regulatory requirements; and
3.3.7 to notify you about changes to our services or products; and
3.3.6. to enable us to provide you with the products and services that you have
requested from us and otherwise performing our legal obligations to you.
3.4. If you have provided your explicit consent and unless and until you advise us to the
contrary, we will also communicate with you about relevant information and
opportunities relating to existing and new products and services which we consider
suitable for you. You have a right to withdraw that consent at any time simply by
contacting firstname.lastname@example.org but please note that this is likely to have an impact upon the products and services we can provide to you.
- Disclosure of Information
4.1 In the standard operation of our business, we may disclose your personal information
to the following (who may be within or outside the European Economic Area):
4.1.1. our associated companies;
4.1.2. successors in title to our business;
4.1.3. our third-party service providers and professional advisors contracted to
provide us with administrative, IT, financial, regulatory, compliance, insurance,
research or other services;
4.1.4. credit agencies;
4.1.5. any organisation or person expressly instructed by you;
4.1.6. any relevant regulatory, governmental or law enforcement authority as required
4.1.7. third parties necessary to provide the products and services requested by you;
4.1.8. introducing brokers and affiliates with whom we have a mutual relationship and
to attorneys acting under powers of attorney with you,
4.2. We will endeavour to ensure that any transfer outside the EEA is lawful and that
appropriate security arrangements apply.
4.3. In order to transfer personal information to third parties in territories that do not yet
retain adequate privacy laws, we will look to enter into agreements with the parties to
whom we may there transfer your personal information ensuring appropriate and
suitable safeguards that would be accepted as adequate within the European
4.4. We require that organisations outside of our group of companies who handle or obtain
personal information as service providers acknowledge the confidentiality of this
information, undertake to respect any individual’s right to privacy and comply with the
Data Protection Legislation and this policy.
- Security of Information
We take the safeguarding of your data very seriously. All personal information in our
possession is held securely. We have put in place appropriate technical, organisational
and security measures to prevent your personal information from being accidentally lost,
used or accessed in an unauthorised way, altered, or disclosed.
In addition, we limit access to your personal information to those employees, agents,
contractors and other 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. Details of these measures may be obtained from email@example.com
We have put in place procedures to deal with any suspected data security breach and will
notify you and any applicable regulator of a suspected breach where we are legally
required to do so.
- Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your relationship
- Data Retention
7.1. We will only retain your personal information for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal,
regulatory, 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 and regulatory requirements.
7.2. However, we may need to maintain records for a significant period of time. For
example: If we hold any personal information in the form of a deed, we will hold this
deed in its complete form for a period of 12 years after our business relationship with
you has ended; we are subject to certain anti-money laundering laws which require
us to retain for 5 years after our business relationship with you has ended a copy of
the documents we used to comply with our customer due diligence obligations and
supporting evidence and records of transactions with you and your relationship with
us; and if we hold any personal information in the form of a recorded communication,
by telephone, electronic, in person or otherwise, this information will be held in line
with local regulatory requirements which will either be 5 years or 10 years after our
business relationship with you has ended.
7.3. In some circumstances we may anonymise your personal information so that it can
no longer be associated with you, in which case we may use such information without
further notice to you. Once you are no longer a client of Reflex Trading we will retain and
securely destroy your personal information in accordance with applicable laws and
- Your rights of access, correction, erasure, and restriction
8.1. Under certain circumstances, by law you have the right to:
8.1.1. Request access to your personal information (commonly known as a “data
subject access request”). This enables you to receive a copy of the personal
information we hold about you and to check that we are lawfully processing it.
8.1.2. Request correction of the personal information that we hold about you. This
enables you to have any incomplete or inaccurate information we hold about
8.1.3. Request erasure of your personal information. This enables you to ask us to
delete or remove personal information where there is no good reason for us
continuing to process it. You also have the right to ask us to delete or remove
your personal information where you have exercised your right to object to
processing (see below).
8.1.4. Object to processing of your personal information 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. You also have the right to object where we are improperly processing
your personal information for direct marketing purposes.
8.1.5. Request the restriction of processing of your personal information. This
enables you to ask us to suspend the processing of personal information about
you, for example if you want us to establish its accuracy or the reason for
8.1.6. Request the transfer of your personal information to another party.
8.2. If you want to review, verify, correct or request erasure of your personal information,
object to the processing of your personal data, or request that we transfer a copy of
your personal information to another party, please contact firstname.lastname@example.org
8.3. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of
the other rights). However, we may charge a reasonable fee if your request for access is
clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in
- 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 the information (or to exercise any of your other rights). This
is another appropriate security measure to ensure that personal information is not
disclosed to any person who has no right to receive it.
- Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection,
processing and transfer of your personal information for a specific purpose, you have the
right to withdraw your consent for that specific processing at any time. To withdraw your
consent, please contact email@example.com. Once we have received notification
that you have withdrawn your consent, we will no longer process your information for the
purpose or purposes you originally agreed to, unless we have another legitimate basis for
doing so in law. Please note however that withdrawing your consent is very likely to impact
the services we can provide to you.
- Questions, Comments and Complaints
change your personal information, or you would like to make a complaint
concerning any action of ours which you consider is in breach of our policy please
contact our Compliance Department directly. We have appointed a data privacy
please contact the data privacy manager at firstname.lastname@example.org
11.2. We would hope to be able to deal with any complaint you may have to your
satisfaction, but 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. You can find details about how to do this on the ICO website at
https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
- How we collect your data
Personal Information may be submitted on our website in two areas:
12.1. Public Area
If you provide your name and address on the public area of our website in order to
request information about our products and services, you may voluntarily provide
additional personal information. You will be asked to provide your Personal
Information in this area for the purposes of registering with us.
13.2. Private Area
If you are already one of our customers and have opened an account with us, you
must use a password to enter our website. A “session cookie” is used to enable you
to leave and re-enter our website without re-entering your password. Our web server
will record the pages you visit within our website. To ensure a good quality of service
we may monitor and record any communication you have with us whether in writing,
by phone or by electronic mail. E-mail is not encrypted to/from either the public or
private areas of this website.
- Card Processing
In accordance with the recommendations of Payment Card Industry Security
Standards Council, customer card details are protected using Transport Layer
encryption — TLS 1.2 and application layer with algorithm AES and key length 256 bit.
- External Links