Tremor

Privacy Policy

CONTENTS

  1. Scope
  2. Personal Data We Collect About You
  3. Purposes for which we will use Personal Data
  4. Sharing Personal Data
  5. European Specific Legal Disclosures
  6. Security
  7. Your Choices
  8. Changes to this Privacy Statement and your duty to inform us of changes

  1. SCOPE

Respecting your privacy is important to Tremor. This Privacy Statement is issued on behalf of the Tremor Technologies Inc. and its affiliates, so references to as “Tremor”, “we”, “us” or “our” are references to the relevant company in the Tremor group responsible for processing your personal data. This Privacy Statement describes the personal data that Tremor collects from you when you access any of our products or services, visit any Tremor website, contact us or request further information regarding a product or service. It also describes how your personal data is used and processed by Tremor and for what purposes we process it. This Privacy Statement should be read together with any other privacy notice or statement that we provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This Privacy Statement supplements the other notices, but does not override them.

  1. PERSONAL DATA WE COLLECT ABOUT YOU

We will collect, use, store and transfer different categories of personal data about you as follows:

  • Identity Data. This includes your name and job title

  • Professional Contact Data. This is the data that allows us to contact you, and includes your email address, postal address, and telephone number.

  • Technical Data. This includes your internet protocol (IP) address (which helps us to determine the location of the device you use to connect to our systems and to determine the number of devices simultaneously accessing the product), your username and password, and the information which we obtain on your technical profile through our use of cookies on your browser. For further information on Tremor’s use of cookies, see section 8 of this Privacy Statement.

  • Professional Profile Data. This is data that you may provide to us about your job role, function and business focus.

  • Tremor Relationship Data. This is the data we obtain from our interactions with you, and includes details of any calls you have made to our help desk, visits made to you by our staff, marketing materials you have received, your email communication with our staff, data about your preferred activities for marketing events or the Tremor events you have attended, and your preferences in receiving marketing communications from us.

  • Product or Subscription Usage Data. This is data we obtain about your usage of our products and services, including when and which products you have used, subscribed for or are enabled to access, and the content and functionality you have used in those products and services.

  • Publicly Available Information. This includes data we obtain from directories, websites, public records or media sources.

  • Referrals. This is the data we obtain from third parties, including intermediaries and other Tremor clients.

Please note that if you fail to provide us with personal data which we are obliged to collect by law, or under the terms of a contract that we have in place with you, then we may not be able to provide our products and services to you, but will notify you if this is the case at the time.

  1. PURPOSES FOR WHICH WE WILL USE PERSONAL DATA

We process personal data for the following purposes:

  • Account setup and administration. We use personal data in order to set up your access to a product or service that you have subscribed for and to manage invoicing and payments.

  • Provision of service. We use the personal data we collect about you to provide you with our products and services and to assist you in your use of these. This includes providing any necessary operational assistance, support and training, and alerting you to product changes or maintenance periods.

  • Sales and marketing. We will from time to time use the personal data we collect about you to contact you by email, post or telephone with information about Tremor, the products and services you use, other Tremor products and services similar to those you use and events that might be of interest to you or your organization. If you submit an inquiry to us on our website or by any other method, then we will use the personal data that you provide to us to respond to your inquiry, and to contact you about any products or services that you confirm to us that you are interested in hearing about. You may ask us to refrain from sending you marketing messages at any time as described in the "Your Choices" section of this Privacy Statement.

  • Product development and improvement. We will occasionally use the personal data we collect about you to ask you to participate in surveys and questionnaires to improve, customise and enhance our products and services. In addition, we can use the data, combined in aggregate form with the personal data we have collected about other users of our professional financial and media products, for statistical purposes, or to plan and implement developments of, and enhancements to our products and product range.

  • Compliance checks and regulatory record-keeping. We also use personal data to conduct compliance checks on our clients, and conduct system monitoring which Tremor is required by law to carry out. We will also need to retain certain personal data for regulatory record-keeping purposes.

Please see the European Specific Legal Disclosures section for the legal basis on which we process the personal data of individuals based in the EU.

  1. SHARING PERSONAL DATA

We do not sell or otherwise disclose the personal data we collect about you, except as described here.

Third Parties

We use other companies as data processors to process certain personal data on our behalf, including service providers who have access to your personal data in order to assist us in our administration of the services. For example, we use:

  • customer relationship management software providers, such as AWS, to assist with the provision of our services and to contact you;
  • KYC and regulatory screening providers who assist us with meeting our compliance obligations.

Third parties that have access to personal data are required by us and by applicable law to protect it in a manner consistent with this Privacy Statement.

Professional Advisers

Our professional advisers including lawyers, auditors and insurers could have access to your personal data during the course of the performance of their professional services to us.

Disclosure for Legal Purposes

We will provide access to your personal data when legally required to do so, including without limitation, to cooperate with regulatory and other government investigations or other legal proceedings.

Third party recipients of your personal data are only permitted to use it for the purposes of performing services on our behalf and in accordance with our instructions. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws.

We may disclose or transfer any information we have about you to third parties in connection with any sale, transfer or merger of all or a portion of our business or assets. Should such a sale, transfer or merger occur, the transferee(s) may use information you have provided in a manner that is consistent with this Privacy Statement.

  1. EUROPEAN SPECIFIC LEGAL DISCLOSURES

Legal Basis for Processing

If you are located in the EU, the below legal bases apply to Tremor’s processing of the personal data that you provide to us. Note that we process personal data on more than one lawful ground depending on the specific purposes for which we are using personal data.

Purpose for processing

Type of data

Lawful basis for processing 

Account set up and administration

 

  • Identity data
  • Professional contact data
  • Technical data
  • Tremor relationship data
  • Professional Profile Data
  • Referrals

Performance of a contract with you

Necessary to comply with a legal obligation

Consent

Provision of service

 

  • Identity data
  • Professional contact data
  • Technical data
  • Professional Profile Data
  • Tradeweb Relationship Data
  • Product or subscription usage data

Performance of a contract with you

Consent

Sales and marketing

 

  • Identity data
  • Professional contact data
  • Technical data
  • Professional profile data
  • Tradeweb relationship data
  • Product or subscription usage data
  • Publicly available information
  • Referrals

Necessary for our legitimate interests (to develop our products/services and grow our business)

Consent

Product development and improvement

 

  • Identity data
  • Professional contact data
  • Technical data
  • Professional profile data
  • Product or subscription usage data
  • Referrals

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Compliance checks and regulatory record-keeping

  • Identity Data
  • Professional Contact Data
  • Technical Data
  • Professional Profile Data
  • Tremor Relationship Data
  • Product or subscription usage data

Necessary to comply with a legal obligation

 

Transfers of personal data outside of the EU

If you are located in the EU, the personal data that we collect from you will be transferred to and processed in the United States by Tremor may also be held on servers globally by some of our service providers, for example AWS. We ensure that any personal data which is transferred by us outside of the EU is appropriately safeguarded by using either of the following legal mechanisms:

  • The transfers of personal data are based on the European Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU.

  • The transfer is to a country that has been designated as providing an adequate level of protection for personal data by the European Commission.

For further information on our legal safeguard mechanisms used when transferring personal data outside of the EU, please contact us at privacy@tremor  .co

Your legal rights if based in the EU

You have certain rights afforded to you under European data protection laws in relation to our processing of your personal data if you are based in the EU:

  • Access: the right to request access to your personal data and to find out how we use it and who it is shared with.
  • Correction: the right to request correction of the personal data that we hold about you or to have incomplete personal data completed.
  • Erasure: the right to request that we erase the personal data that we hold about you in certain circumstances prescribed by EU law. Your request for erasure will be balanced against our legitimate requirements to process your personal data, including our regulatory record-keeping requirements.
  • Restriction: the right to require us to restrict our processing of your personal data in certain circumstances prescribed by EU law. Your request for restriction will be balanced against our legitimate requirements to process your personal data.
  • Objection: the right to object to our processing of your personal data where we are relying on a legitimate interest and your specific situation means that you wish to object to processing on this ground as you feel that it impacts your fundamental rights and freedoms. You may also object to our processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms.
  • Portability: the right to receive the personal data that we collect from you in a structured, commonly used and machine readable format, and the right to request that we transfer such personal data to another party.
  • Withdraw consent: where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time.
  • Contact details for EU data requests and complaints

You may at any time submit a personal data query, a request to exercise any of your above rights, or a complaint by contacting us by email or post at:

Tremor Technologies, Inc.

PO Box 8176 #18052

Greenwich, Connecticut 06836-8021 US

For the attention of: Data Protection Representative

Email: privacy@tremor.co

We aim to respond to all legitimate requests within one month, except where your request is particularly complex or you have made a number of requests, in which case we may take longer to respond to you, but will in any case notify you of this and keep you updated accordingly.

Note that you also have the right under EU data protection laws to make a complaint at any time to the applicable supervisory authority, which in the UK is the Information Commissioner’s Office (ICO).

Data retention period

In the EU, we are required by law to retain certain information about our customers (including contact, identity, financial and transaction data) for a minimum of five years after they cease being customers for regulatory and tax purposes.

We will retain personal data if it is anonymised (i.e. so that you are no longer identifiable) for statistical and research purposes for an indefinite period of time without further notice.

  1. SECURITY

We maintain appropriate administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data you provide to us. We also limit access to your personal data to those employees, agents and contractors and other third parties who have a business need to access your data. They will only process your information in accordance with our instructions and are subject to a duty of confidentiality.

 

  1. YOUR CHOICES

You may contact us to access the personal data you provide to us and to ask us to update, correct, or delete it from our databases, where it is legally permissible for us to do so. You may also request that we cease using your personal data for marketing purposes. If you do not wish to receive marketing emails and /or marketing materials from Tremor about the products and services we provide, or if any of your contact details are incorrect, please let us know by calling us on:

 contacting us by email or post at:

Tremor Technologies, Inc.

PO Box 8176 #18052

Greenwich, Connecticut 06836-8021 US

For the attention of: Data Protection Representative

Email: privacy@tremor.co

 

  1. CHANGES TO THIS PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF         CHANGES

This Privacy Statement may be updated periodically. We will indicate below when it was most recently updated and inform you, in this Privacy Statement, through email and/or a notice on the appropriate Tremor website, of any significant changes

Last updated: August 1, 2019

It is important that the personal data that we hold about you is correct and up-to-date, so please notify us of any changes to your personal data during your relationship with us.