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 FirstScrap :
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 anymore.
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 services.
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 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 consent.
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 directly also.
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.