At FirstScrap we understand the importance of maintaining the confidentiality of
your personal information and are committed to ensuring the security of any information
collects uses and manages personal information from you. FirstScrap is committed
to safeguarding your privacy. By opening a trading account with FirstScrap, you
give consent to such collection, processing, storage and use of personal information
by FirstScrap as explained below.
COLLECTION OF PERSONAL INFORMATION
To provide financial services to you efficiently and accurately, when you apply
to register to use one or more of our services, we will ask you for certain personal
information. FirstScrap retains the right to check the accuracy of the data in the
database by occasionally asking you for updated data or a verification of the accuracy
of the aforementioned.
The kind of personal information FirstScrap may collect can include (but is not
limited to): Full name; Date of birth; Place of birth; Home and business addresses;
Home and business telephone numbers; Email address; Passport number/or ID number;
Information on employment status and income; Information about previous trading
experience; Information on education and profession; Tax Domicile and Tax ID Number;
Financial Data (such as bank account and payment card details); Transaction Data
(such as details about payments to and from you); Technical Data (such as login
data, IP address, browser plug-in types and versions, time zone setting and location,
browser type and version, operating system and platform and any other technology
on the devices you use to access this platform); Profile Data (such as your username
and password, your interests, preferences, feedback and survey responses); Usage
Data includes (such as information about how you use our platform, and services);
and Marketing and Communications Data (such as your preferences in receiving marketing
from us and our third parties and your communication preference).
Also, FirstScrap collects, uses and shares Aggregated Data such as statistical or
demographic data. Aggregated Data may be obtained from your data but is not deemed
personal data in law as this data does not in any way reveal your identity. For
instance, we may decide to aggregate your Usage Data to determine the percentage
of users accessing a specific feature of our platform. Nevertheless, if we combine
or connect Aggregated Data with your data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
line with this privacy notice.
FirstScrap may gather certain information about your usage of our services. This
may include certain information from which you and/or your company can be recognised.
Such information include the times you log in, your volume of the usage of the services,
the kinds of data, systems and reports you access, the locations from which you
log in, duration of sessions and other related data. The information collected may
be also lawfully derived from third parties, including public authorities, companies
that have introduced you to FirstScrap, card-processing companies, and publicly
available sources that we are lawfully allowed to process such data.
Any electronic and/or telephone communication with us is usually recorded as the
sole property of FirstScrap and constitutes a proof of your communication with us.
You can choose to supply any or all of the personal information needed. Nevertheless,
missing information may lead to our being unable to open or maintain your account
and /or to render our services to you.
USE OF YOUR PERSONAL INFORMATION
FirstScrap gathers, processes and manages the information which allows us to perform
our contractual obligations to you in compliance with our legal obligations.
Below are some main purposes for which your personal information is processed by
Performance of a contract: FirstScrap processes your data so to provide you with
our services, and to be able to complete our acceptance procedure so to enter into
a contractual relationship with you. To complete your onboarding, FirstScrap needs
to verify your identity, perform the customer due diligence as per the regulatory
obligations, and we need to use the acquired details to effectively manage your
trading account with FirstScrap.
Compliance with legal obligations: Many legal obligations are enforced by relevant
laws to which FirstScrap is subject, as well as statutory requirements, such as
anti-money laundering laws, corporation laws, financial services laws, tax laws,
and privacy laws. Additionally, there are several supervisory authorities whose
laws and regulations apply to FirstScrap, which impose necessary personal data processing
activities for credit card checks, identity verification, payment processing, and
compliance with relevant court orders.
To safeguard legitimate interests: FirstScrap processes personal data to safeguard
the legitimate interests pursued by FirstScrap or by any third party, where the
legitimate interest is when FirstScrap has a business or commercial reason to use
your information. However, when we do this, it is not to go unfairly against you,
but in line with what is best for you. Such processing activities include the following:
Launching court proceedings and arranging our defence in any litigation procedure;
means and processes FirstScrap undertakes to provide for the our IT and system security,
deterring potential crime, asset security, admittance controls and anti-trespassing
techniques; techniques to manage business and for further development of the services;
and effective risk management.
For the sake of internal business and record-keeping: It may be needed to process
your data for the sake of internal business and record-keeping, which in our legitimate
interest is required to comply with our legal obligations. FirstScrap will also
keep records so as to ensure that you comply with your contractual obligations in
line with the agreement governing our relationship with you.
For the sake of legal notifications: On different occasions, the law compels FirstScrap
to advise you of certain modifications to the services, platform or laws. FirstScrap
may need to inform you of the modifications regarding to our services or platform;
thus, FirstScrap will be obliged to process your personal information to send you
such legal notifications. You will continue to receive such information even if
you opt not to get direct marketing information from FirstScrap.
For the sake of Marketing: FirstScrap may use your data for the sake of research
and analysis, and your trading history to deliver any analysis, reports, or campaigns
that may interest you to your provided email address. Kindly note that you always
have the right to edit your option if you do not wish to receive such communications
To ensure the improvement of our services and platform: FirstScrap may use the personal
information provided by you to ensure the highest standards when providing our services
and for our platform.
COLLECTION OF PERSONAL INFORMATION
FirstScrap will not disclose your personal information without your prior consent
however, depending on the service concerned and particular restrictions on sensitive
information, this means that personal information may be disclosed to:
Service providers and specialist advisers to FirstScrap who have been contracted
to provide FirstScrap with administrative, financial, research, insurance, or other
Introducing brokers or partners with whom FirstScrap has a mutual relationship (any
of whom may be within or beyond the European Economic Area) Credit reporting or
reference agencies, fraud prevention, third authentication service providers, anti-money
laundering purposes, valid identification or due diligence checks of you Credit
providers, courts, tribunals and regulatory agencies as agreed or authorized by
law Any person authorized by another person, as stipulated by that person or the
contract To an Affiliate of the FirstScrap or any other company in the same group
of the FirstScrap company.
In case such disclosure is required by law or any regulatory authority, it will
be made for FirstScrap to comply with such legal obligations, protect itself from
any potential fraud, and fulfil service provider agreements. When such disclosure
is expected, it will be made on a ‘need-to-know’ basis, except otherwise instructed
by the regulatory agency. In general, FirstScrap requires that organizations not
under FirstScrap who handle or obtain personal information as service providers
to FirstScrap acknowledge the confidentiality of such information, promise to respect
any individual's right to privacy and abide by the Data Protection Principles and
In certain circumstances, FirstScrap may pass on information to third parties if
FirstScrap is legally required to do so or if FirstScrap is authorized under our
contractual and statutory obligations or if FirstScrap has been provided with your
FirstScrap may also disclose your personal information to third parties if FirstScrap
is under a duty to disclose or share your data to comply with any legal obligation
or to enforce or apply our Terms.
HOW LONG WE KEEP YOUR DATA
FirstScrap will keep your data for as long we have a business relationship with
you. Even after requesting a deletion of your data, we may still retain your data
for many reasons such as fraud prevention, court cases, and so on.
YOUR RIGHTS BASED ON YOUR PERSONAL INFORMATION
By legislation, FirstScrap is required to respond to any personal data requests
within 30 days, except the kind of request demands more time for proper investigation
and assessment. The rights available to you regarding the personal information FirstScrap
holds about you are outlined below:
Right to access your data. This allows you to receive a copy of the personal data
FirstScrap holds about you.
Right to request correction of the personal data FirstScrap holds about you. This
allows you to correct any incomplete or inaccurate data FirstScrap holds about you.
FirstScrap may request extra information and documentation to validate the need
for such a request.
Right to request for the deletion of your personal information on our platform.
You can ask FirstScrap to erase your data, applying your right “to be forgotten”,
where there is no good reason for FirstScrap to continue processing it. This request
to delete your data will lead to the closure of your account and termination of
our relationship with you.
Right to request to ‘block’ or suppress the processing of your data in certain circumstances,
such as if you contest the accuracy of such personal information or object to us
processing your information. It will not stop FirstScrap from storing your personal
information. FirstScrap will inform you before FirstScrap decides not to agree with
any requested restriction. If FirstScrap has disclosed your personal information
to others, FirstScrap will inform about the restriction if possible. If you ask
FirstScrap, if possible and lawful to do so, FirstScrap will also tell you with
whom FirstScrap has shared your personal information so that you can contact them
Right to object to the processing of your data for any direct marketing. This also
includes profiling in as much as it is related to direct marketing. If you object
to processing for direct marketing purposes, then FirstScrap shall stop the processing
of your data for such purposes.
Right to object, at any time, to any decisions that FirstScrap may take that are
purely based on automated processing (including profiling). Profiling involves using
technology that helps us make decisions automatically, based on your data that FirstScrap
collects from you or third parties.
HOW FirstScrap PROTECTS YOUR INFORMATION
FirstScrap endeavours to ensure the protection of the information submitted to us,
both during transmission and once we receive it. FirstScrap maintains appropriate
administrative, technical and physical safeguards to protect Personal Data against
accidental or unlawful destruction, accidental loss, unauthorized alteration, misuse,
unauthorized disclosure or access, and any other unlawful form of processing of
the Personal Data in our possession. This includes, for instance, firewalls, password
protection and other access and authentication measures.
Nevertheless, no means of transmission over the Internet, or means of electronic
storage, is 100% secure. FirstScrap cannot ensure or warrant the security of any
information you transmit to us and you do so at your own risk. We also cannot guarantee
that such information may not be accessed, disclosed, altered, or destroyed by breach
of any of our physical, technical, or managerial safeguards. If you strongly believe
your Personal Data has been compromised, please contact us immediately.
FirstScrap may store your information in its databases for reference to answer queries
or resolve problems, provide improved and new services and to meet any legal data
retention requirements. This means we may retain your information after you stop
using the platform or our services or otherwise interacting with us.