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Your privacy is of paramount importance to us. At Hantec Markets we protect personal data and confidentiality of the information and respect the privacy rights of our existing and prospective customers.

Hantec Markets collects data to operate effectively and provide you with a valuable service while ensuring that your needs are met.

This privacy notice explains what personal data we collect from you in connection with the provision of our products or services to you or from your use of our products and services, as well as through our interactions with you through our website or applications. This notice also outlines how the data that we collect is used.

Data Controller

This Privacy Notice applies to the data processing activities carried out by Hantec Markets Limited who acts as a Data Controller of your personal information.

Hantec Markets Limited is registered in England and Wales, company number 06819047, principal place of business Second Floor, 11–21 Paul Street, London EC2A 4JU, registration number with the Information Commissioner is ZA188388.

If you have any questions about this notice or wish to exercise your rights in relation to your personal information, please contact the Data Protection Officer:

• Call: +44 (0) 207 036 0882
• Email: [email protected]
• Write to us: Compliance Department, Hantec Markets, Second Floor, 11–21 Paul Street, London EC2A 4JU

What Type of Personal Data We Collect and How We Collect It?

The data we collect depends on the context of your interactions with us, the choices you make, including the products and services you use or wish to start using. The data we collect about you can include the following:

• Name and contact data: We collect your full name, email address, personal postal address, phone number, and other similar contact data
• Demographic data: We collect data about you such as your date and place of birth, gender, country, and preferred language.
• Location data: For certain products and services, we collect imprecise data about your location that includes, for example, a location derived from your IP address.
• Profession and employment details: We collect details of your employment and your source of income.
• Government-issued photographic identification: We collect copies of passports, national ID cards, driving licenses and other acceptable forms of ID that contain photos.
• Financial and tax information: We collect information about your income, assets and liabilities, balances of your accounts, trading and financial statements, bank details, tax identification numbers and other identification numbers used for tax purposes.
• Trading information: We keep records of the products you trade with us and their performance.
• Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
• Content: We collect the content of all telephone conversations and electronic communications between us that result in placing and/or closing an order or a trade, including communications that are intended to result in placing and/or closing an order or a trade, irrespective of the outcome.

We collect the content of files and communications we receive from you, when necessary to provide you with the products and services you use or intend to use. This includes files and communications sent and received by us via Outlook, our Client Portal and by post.

• To perform essential business operations (including monitoring and improving ) and provide the products and services we offer;
• To perform administration on the account you may hold with us on an on-going basis, including keeping records we hold accurate and up-to-date;

• Other companies within the Hantec Group.
• Vendors, service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, compliance, legal, regulatory, insurance, research or other services and who work on our behalf for the purposes described in this notice and may need access to personal data to provide those functions.

In such cases, the contractors must abide by our data processing agreements and are not allowed to use personal data they receive from us for any other purpose.

• Introducing brokers with whom we have a mutual contractual relationship;
• Anyone authorised by you

We may also disclose personal data to:

• Courts, tribunals, law enforcement or other government agencies, applicable competent authorities as required by law or requested to comply with applicable law for internal investigations and reporting or respond to valid legal process;

The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data to other jurisdictions outside the European Economic Area (EEA). Such countries may not have the same data protection laws as your jurisdiction. We have put in place the Standard Contractual Clauses approved by the European Union Commission for such transfers of personal data. To the extent we transfer your information outside the EEA, we will ensure that transfer is lawful and that there are appropriate security arrangements. Please contact us on [email protected] should you require more information on international data transfer arrangements

Security of Personal Data

• Records of identification evidence (customer due diligence/KYC) are kept for a period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
• Records relating to all orders and all transactions carried out by us on behalf of our clients containing all the information and details of the identity of the client, and the information required is kept for the period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
• Records of communications, including telephone and other electronic communications, are retained for five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.

If you have opted out of receiving any marketing communications from us we will add you to a “do not contact” list to ensure we comply with your opt-out right and that your details will not be put back on the marketing list at later stages.

Data subject rights

The GDPR provides the following rights for you:

• The right to be informed – If you ask us, we will provide you with various pieces of information about the data processing activities undertaken by us. This information is provided in this Privacy Notice.
• The right of access – If you make a request, we will provide you with confirmation whether your personal information is being processed by us and a copy of that personal information. Should you wish to see your own collection data, request for information can be made by email [email protected].
• The right to rectification – If the data we hold about you is inaccurate or incomplete you have the right to rectify it. If we have disclosed your information to others for the purposes described in this notice, we will inform them about the rectification where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
• The right to data erasure (the right to be forgotten) – You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it and we have no compelling reasons or legal basis for holding it or, where applicable, you withdraw your consent. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will inform them about the erasure where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
• The right to restrict processing- In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
• The right to restrict processing- In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
• The right to data portability – This allows you, in certain circumstances, to obtain personal information you have provided us with and move, copy or transfer it between service providers of your choice.
• The right to object- You can ask us to stop processing your personal information and we will do so, if:

– Processing is based on our legitimate interests, except if we can demonstrate overriding compelling legitimate grounds to continue processing or the processing is for the establishment, exercise or defence of legal claims;

– Processing is for direct marketing; and

– Processing is for purposes of historical research and statistics

You can always choose whether you wish to receive promotional e-mails or telephone calls from Hantec Markets. You can also opt-out of (or unsubscribe from) receiving marketing emails at any time by clicking on the unsubscribe link at the bottom of the latest email you received from us.

Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision when:

• it is based on automated processing; and
• it produces a legal effect or a similarly significant effect on you.

At Hantec Markets we do not make decisions about you based solely on an automated process without any human involvement including profiling (automated processing of personal data to evaluate certain things about you).

The right to lodge a complaint

If you have concerns or complaints about any aspects of our privacy practices, you can contact us by email to [email protected] and this will be investigated promptly by the Data Protection Officer.

If you are dissatisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Risk Disclosure

This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Conduct Authority [Registration No. 502635].

Warning: demo platform

The virtual funds available via your demo platform allow you to familiarise yourself with our trading platforms, and any gains or losses incurred while trading in a demo environment are not suggestive of results you may achieve when trading on a live platform. Access to your demo platform is only valid for 30 days, which will be terminated thereafter, however you will be able to trade in a live environment once your account has been opened and funded.

Warning: internet trading risks

There are risks associated with using an internet trading system. These include, but are not limited to: error in hardware, software, internet connection or any force majeure (i.e. flood; extraordinary weather condition; earthquake, or other act of God; fire; war; insurrection; riot; labour dispute; accident; action of government; communications or power failure; or equipment or software malfunction). HML or our affiliates (‘we’, ‘our’ or ‘us’) cannot control the signal power, its reception or routing via internet, configuration of your equipment or reliability of its connection. Therefore, we cannot be responsible for any communication failure, distortion or delay (although we will attempt to minimise the possibility of system failure). Please call us immediately if you are unable to access your account and we will execute your orders over the phone. Please note for security reasons you will need to go through our identification process before we accept any orders from you. If we are unable to identify you we will not be able to carry out your orders.

Warning: risks of margin trading

Trading in currency and bullion, particularly margin trading, involves the potential for profit as well as the risk of loss. This may vastly exceed the amount of money you commit to any trade or transaction. Movements in the price of currency or bullion rates are influenced by a variety of factors of global origin, many of which are unpredictable. Violent movements in the price of foreign exchange or bullion rates may result in action by the market. As a result you may be unable to settle adverse trades. Our staff are unable to guarantee the accuracy of any market predictions (should they offer such predictions) and cannot guarantee a maximum loss that you may suffer.

General advice warning

Any general advice provided by us, or on our website, or via our trading platform, does not take into account your financial situation, personal objectives or needs. CFD and currency trading is not suitable to all. We highly recommend you practice risk free on a demo account before investing any funds. You should then consider your objectives, financial situation and needs, and take all reasonable steps to fully understand the possible outcomes of trades and strategies that can be employed.

Copyright

Except where noted otherwise, all material on the website (the “Site”) is our copyright with all rights reserved. No part of the materials on this Site, including but not limited to the text, graphics and html code, may be reproduced or transmitted in any form by any means without our prior written permission.

Your Use of the Site

You may download materials from this Site for non-commercial and personal use only, provided that the intellectual property rights or other proprietary notices remain unchanged and visible. No right or interest in any downloaded materials is transferred to you as a result of any such downloading. You agree that you will not otherwise copy, modify, display, distribute, sell or transmit any material on the Site in any manner without our prior written permission. Furthermore, you shall not, under any circumstances, use the Site for any purpose that is prohibited by these terms and conditions or any applicable laws.This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Conduct Authority [Registration No. 502635].

Introduction

As a financial institution, Hantec Markets Limited (hereafter “Hantec Markets”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, Hantec Markets will take all sufficient steps to establish, implement and maintain an effective Conflicts of Interest Policy to prevent or mitigate any risk that may damage the interests of our clients.

This statement discloses the conflicts of interest that you, as an existing or potential customer, might face when engaging in business dealings with Hantec Markets; the laws and regulations subject to conflicts of interest that Hantec Markets is required to comply with; and the Policy Hantec Markets adopts for the aim of preventing and managing the conflicts of interest.

Laws and Regulations

The FCA recognises that conflicts of interest exist in the financial services industry and does not aim to eliminate them. Nevertheless, Principle 8 of the FCA’s Principles for Business (PRIN) sets out that a firm must manage conflicts of interest fairly, both between itself and its customers, and between a customer and another customer. Furthermore, within the Senior Management Arrangements, Systems and Controls (SYSC) of the FCA handbook, in particular the SYSC 10, firms are required to manage the conflicts so that they do not damage the customers’ interest. Under the Markets in Financial Instruments Directive (“MiFID II”),  Hantec Markets is required to maintain and operate effective organisational and administrative controls to take all appropriate steps to identify, prevent or manage conflicts of interest.

Identification of Conflicts

A conflict of interest may arise where our interests or those of a member of our staff could conflict with a duty we have to a client. Part of staff training in this area is to recognise and remediate or escalate potential conflicts in the course of business. However, to help identify potential conflicts of interest, we have considered a number of areas. The following services and activities have the possibility to give rise to a conflict of interest and potentially, but not necessarily, be detrimental to the interests of our clients:

• Hantec Markets may receive or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer;
• Hantec Markets  may carry on the same business as the customer;
• Hantec Markets is likely to make a financial gain, or avoid a financial loss, at the expense of the customer;
• Hantec Markets may have a financial or other incentive to favour the interest of another customer(s) over the interests of the customer;
• Hantec Markets may have an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome; or
• Hantec Markets may have an interest in maximising trading volumes in order to increase commission revenue, which opposes the client’s objective to minimise transaction costs.

These are general potential conflicts that will be managed in accordance with this Conflicts of Interest Policy. Any additional conflicts will be recorded in the Register of Conflicts of Interest.

Management of Potential Conflicts Identified

Hantec Markets keeps records of the business activities or services carried on by us (or which are carried on our behalf) so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers.

Employees are required to report specific potential conflicts of interest in writing to the Compliance department as soon as practicable. To identify the potential conflicts of interest that require reporting, employees take into account whether Hantec Markets or its employee:

• could be in a position where the ability to act in a client’s best interests is potentially affected by any other matter
• is aware of any situation where the interest of one client may conflict with those of another
• is likely to make a profit or avoid a loss at the expense of the client
• has an incentive, financial or otherwise, to favour the interest of one client or group of clients over another;

Trading for Group Companies

Other sister companies within the Hantec group may hold accounts with Hantec Markets. Such accounts will be treated the same as any other client accounts with regard to the priority and execution of orders.

Personal Account Dealing

Hantec Markets has policies and procedures to monitor employees’ personal account dealing. Hantec Markets requires its employees to apply good judgement and act with integrity, taking all appropriate steps to avoid personal Conflicts in their personal account dealings and proactively escalate personal conflicts that do arise.

Best Execution

Hantec Markets’ Execution Policy is created to ensure that when executing orders, Hantec Markets acts in the client’s best interest. This applies irrespective of any potential or existing conflicts of interest and reduces the risk of Hantec Markets acting in favour of itself or a client over another client.

Managing Conflicts of Interest

Hantec Markets maintains a register of the potential conflicts of interests that have been identified. The records contained within the register allow the appropriate management of specific conflicts, whilst information on the management of general type of conflicts of interest is recorded in this Policy.

Review

Hantec Markets is devoted to provide more services and products to meet our customers’ demand. At the same time, Hantec Markets frequently reviews and assesses our conflicts of interest policy so that it can ensure the adequacy of such policy in compliance with our regulatory obligations.

Hantec Markets Policy

As required by law, Hantec Markets implements and maintains an effective Conflicts of Interest Policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.

Hantec Markets’ conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Dealing policy, Gifts and Inducement policy, public interest disclosure policy; acting in the best interest of the clients; and in some cases declining to act for a customer or potential customer. These are also monitored on an ongoing basis within the company’s Compliance Monitoring Programme.

Hantec Markets also maintains and operates effective product governance arrangements to ensure that our products meet the needs of our clients and remain appropriate at all times.

Disclosure

Whilst Hantec Markets is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a customer. In such a case, as a solution of last resort, Hantec Markets shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question.

Scalping is a form of trading which we consider to be an unacceptable practice and a type of market abuse. Scalping might be wrongfully used to return profits by taking advantage of internet latencies, delayed prices, off market/bad prices or through high volumes of transactions targeting tick fluctuations (rather than price movements) where trades are opened and closed very quickly.

If, in our sole discretion, we consider you to have partaken in this form of scalping, it will be considered as a breach of our Terms and Conditions and as such we reserve the right to:

• Make immediate changes to your account, including but not limited to, the liquidity provided by us and the spread quoted.
• Immediately terminate your account and your access to our servers.
• Void any trade (i.e., treat the trade as if the trade had never taken place) which was part of any Scalping activity.
• Close any trade, which was part of any Scalping activity, on the basis of our current market price.

We can exercise the above rights even if you have entered into (or refrained from entering into) such arrangements with third parties relating to the relevant trade and even if you may suffer a trading loss as a result.

Please be advised that all trading activity is monitored closely, and in the event it is identified that you are Scalping we reserve the right to close your account with immediate effect.

This statement details Hantec Markets Limited’s policy with regard to FCA Principle 6: “A firm must pay due regard to the interests of its customers and treat them fairly”.

The fair treatment of customers is one of the key principles of the Financial Conduct Authority in the UK. The FCA requires firms to be able to demonstrate that they are consistently treating their customers fairly. At Hantec Markets the Directors and Senior Management are committed to ensuring that the FCA principle of Treating Customers Fairly (TCF) is applied in all aspects of our business activities.

We recognise that fair treatment of our customers is about adding value to the service we offer. To ensure that we are continuously providing our customers with a valuable service we aspire to:

• protect the interests of our customers in all areas of our dealings with them and at each stage of the product life cycle, from promotion right through to after-sales service
• meet the needs of each customer by offering a transparent and professional service, and to constantly review our service to identify areas where we can improve it

Our Commitment to you

• To ensure the products that we offer are appropriate for you and are consistent with your needs;
• To provide timely and best execution at all times;
• To maintain a superior level of system and platform availability;
• To ensure all staff implement TCF in their daily business activities;
• To ensure your complaints are assessed fairly and impartially and handled professionally should you ever become unhappy with our service;
• To encourage staff to recommend improvements to service following customer complaints;
• To ensure that promotional material is clear, compliant and appropriately targeted ;
• To provide accurate, complete and timely communications;
• To ask for and listen to your feedback and place your interests first.