Quadrature office breakout space

Privacy Notice

This privacy notice applies to the processing of personal data that Quadrature Capital Limited (“Quadrature“, “we“, “us” or “our“) may from time to time process in relation to our and our affiliates’ business activities.

For our Candidate Privacy Notice, please click here.

WHAT IS PERSONAL DATA?

The term personal data describes any information relating to an individual (“you”), where the individual is identified or identifiable, directly or indirectly, by reference to that information.

Examples of personal data include:

  • names;
  • residential addresses;
  • email addresses such as name.surname@company.com;
  • identification card numbers;
  • location data (for example the location data function on a mobile phone); and
  • internet protocol addresses.

HOW WE COLLECT INFORMATION ABOUT YOU

We may collect personal data about you through:

  • information provided by you directly to us or by another person acting on your behalf when you or such other person contacts us:
    • through our website;
    • by email;
    • by post;
    • by telephone; or
    • in person,
  • information that we obtain in relation to any transactions or other business activities between you (or your employer) and us (such as any performance of services to us);
  • information provided by you directly to us or by another person acting on your behalf in relation to (i) any of our events that you may attend or participate in and/or (ii) you gaining access to any of our offices or other premises;
  • ecording and monitoring of telephone conversations and electronic communications with you as described below; or
  • the use of Internet “cookies”, as described further below.

We may also, in some circumstances, receive personal data about you from third parties, such as current or prospective service providers, trading counterparties, regulatory or law enforcement agencies, credit reference agencies, or agencies conducting background checks. Personal data may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

WHY WE COLLECT INFORMATION ABOUT YOU

We may collect and use your personal data for the purposes of managing the relationship between you (or your employer or client). For example, if you are involved in the provision of services to us (whether in your personal capacity or through services provided by your employer or client), we will process your personal data as reasonably necessary for us to manage such relationship. If our relationship is directly with you, we process your personal data because: (i) it is in our legitimate interests, (ii) it is necessary for the performance of a contract between you and us, and/or (iii) it is necessary for compliance with a legal obligation to which we are subject.

We may collect and use your personal data if we or one of our affiliates is evaluating whether to give you (or an organisation of which you form a part) a donation for your charitable purposes. We will process your data as reasonably necessary for (i) us to do due diligence on you or your organisation to determine whether a donation will be made, (ii) monitor or audit the use of the donated funds and (iii) us to generally manage the relationship and to comply with our obligations relating to any donation. We rely on the following bases when processing your personal data for these purposes: (A) our legitimate interests, (B) to comply with our legal obligations and (C) to perform our obligations under any grant agreement that may be put in place between you and us (or our affiliates). For example, we have to do background checks on your and/or your organisation to comply with legal obligations and to generally to ensure that you or your organisation is a good match with our charitable objectives.

We may collect and use your personal data in the event that you decide to contact us via email, social media or other channels, as necessary for us to reasonably act on any query/request/comment you make to us. We are relying on our legitimate interests when we do this.

We may collect and use your personal data if you decide to attend or participate in any event that we may organise, in each case as reasonably necessary for us (or third parties acting on for us) to organise and run the event (for example, we will need your personal data in order for you to (i) access any premises for the event or (ii) use any mode of travelling relevant to such event). Please also note that we typically have photographers present during our events, which means that your personal data may be included in any media that such photographers may produce for the purposes of recording such events. We process your personal data in the scenarios described in the paragraph because it is in our (or a third party’s) legitimate interests to do so.

We may collect and use your personal data as necessary for monitoring and analysing our activities and complying with applicable legal or regulatory requirements (for example, we record telephone and electronic communications between our business and third parties). We do this in order to comply with our legal/regulatory obligations and/or when it is in our legitimate interests (e.g., to protect our confidential information).

We may collect and use your personal data for recruitment activities (for example, when we try to identify potential candidates to join our business). For example, we (or a service provider acting for us) may collect your personal data from public online sources (such as LinkedIn) for such purposes. We do this because it is in our legitimate interests to do this. Further information about processing of personal data in relation to our recruitment activities can be found here .

We will not sell your personal data or use it for direct marketing purposes. We will use one of the permitted legal bases for collecting and processing personal data, as set out in the UK General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and any other data protection or privacy laws applicable to our processing of your personal data (“Data Protection Laws”), as further specified above with examples.

You may request more information on the legal basis for collecting and processing your data when we request personal data from you. When we are relying on our legitimate interests as the basis for processing, you have the right to object to the use of your personal data by us. However, even if you do object, this does not necessarily mean that we are under an obligation to cease the relevant use.

WHAT ARE THE CONSEQUENCES OF FAILING TO PROVIDE YOUR PERSONAL DATA?

A refusal to provide us with personal data may, depending on the purpose for which your personal data is required, have various consequences, such as us being unable to communicate with you (or any organisation you may be acting for), the termination of any service or other contractual arrangement between us and you (or any organisation you may be acting for), refusal of your entry to our premises or participation in any event we may organise, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

THE TYPES OF PERSONAL DATA WE MAY COLLECT AND USE

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, email addresses, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, work and educational history, photographs, copies of identification documents, bank account details, credit history, criminal and administrative offences, or other personal data as may reasonably be expected to be processed in the course of the types of activities detailed above.

DO WE USE AUTOMATED DECISION-MAKING PROCESSES?

No.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We may (to the extent necessary for the purposes for which we collect your information), share your personal data with third parties, such as:

  • our affiliates, including Quadrature Climate Foundation, or other entities that are part of our group, or with our clients;
  • any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
  • our internet, IT, telecommunications and other service providers, including legal advisers, accountants, invoice/payment processors, that we or our affiliates may use in the course of our business activities further described above;
  • any third-party service providers that we use to organise and run our events and who may provide services to us in relation to such events;
  • third parties that manage access to any of our premises that you may visit;
  • credit reference agencies and other third parties conducting background checks in the context of counterparty due diligence (including in relation to both commercial and charitable relationships);
  • any person, as directed by you; or
  • any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

TRANSFERS OF PERSONAL DATA TO COUNTRIES OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the UK, such as to jurisdictions where we or our affiliates conduct business or have a service provider, including jurisdictions that may not have the same level of data protection as that afforded by the Data Protection Laws. In these circumstances, we take steps to ensure that the transfers to such countries take place in accordance the requirements of Data Protection Laws, such as by requesting appropriate contractual undertakings in our legal agreements with service providers if the laws of the country to which your personal data is transferred do not offer an adequate level of protection.

Occasionally, we may transfer your personal data to third countries that do not offer the same level of protection as Data Protection Laws without additional contractual undertakings or other measures. This might be necessary in the event you participate in our events that take place in a third country. In order to enable your participation in such events, we (or a third-party service provider acting for us) would need to transfer your personal data to our service providers in such third countries so that such service providers may provider their services, such provision ultimately benefiting you.

FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will generally keep personal data about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period as required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

WHAT ARE YOUR RIGHTS?

You may have the following rights with respect to our processing of your personal data, namely the right to:

  • request that we provide you with a copy of your personal data (you will receive your data in a structured, machine readable format);
  • request that we correct the personal data we hold about you (if the data is inaccurate, incomplete or otherwise incorrect);
  • request that we delete the personal data we hold about you (where we have no legitimate reason to keep the data or you’ve exercised your legal right to object to processing);
  • object to processing where we are relying on legitimate interests as the basis for processing;
  • request the restriction of processing of your personal data, which enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
  • request the transfer of your personal data to another person.

We do not generally rely on your consent in our processing of personal data. However, where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Quadrature processing your data, this will not affect any processing which has already taken place at that time. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) contact us at +44-20-3743-0400; (ii) submit a webform request here or (iii) send an email to privacy@quadrature.ai .

We will confirm receipt of your request within five days, and we will respond within 30 days (or, if your request is complex or we receive numerous requests within a short period of time, within 90 days). Any information will be provided to you free of charge.

HOW TO CONTACT US

Please contact us on +44(0) 20 3743 0400, by email at privacy@quadrature.ai or by writing to the following address Quadrature Capital Limited, The Leadenhall Building, 122 Leadenhall Street, London, EC3V 4AB for any questions about this privacy notice or requests with regards to the personal data we hold.

COMPLAINTS

If you have unresolved concerns, you have the right to complain to your local data protection authority. The UK’s data protection authority is the ICO and you can make complaints at https://ico.org.uk/make-a-complaint/. Further information is available on the ICO’s website.

USE OF COOKIES

Our policy regarding the use of cookies on this website can be found here.

RECORDING AND MONITORING OF COMMUNICATIONS

We record and monitor telephone conversations and electronic communications (including emails) with you for the purposes of:

  • ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
  • ensuring compliance with our regulatory obligations; or
  • detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of seven years, or such other longer period as we (or relevant legislators or regulators) may determine from time to time.

UPDATES TO THIS PRIVACY NOTICE

This privacy notice will be updated from time to time. We will update the date at the bottom of this privacy notice accordingly and encourage you to check for changes to this privacy notice. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this privacy notice, as required by applicable law.

Effective from: 3 May 2024.