Legal

Privacy policy

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This Privacy Policy (the Policy) describes how Copper collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites.

We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy describes:To find out more click on the sections.

General Information

In this Policy when we refer to Copper or “we”/”us”/”our” we mean Copper Technologies (UK) Ltd and also other companies and entities that are associated with us. Our registered office is at 64 North Row, 3rd Floor, London, W1K 7DA. You can find contact details in the Contact us section of our website.

Who we are

Copper is a FinTech scale-up and go-to provider of safeguarding and trading infrastructure for digital assets. We create and maintain the systems that enable vast sums of crypto-assets to move quickly and securely between exchanges and hedge funds, private banks and family offices. When we collect and use your personal information, Copper is the controller and processor of data.

Purpose of this Policy

Copper takes your privacy very seriously and is committed to protecting your personal information. This Policy sets out the way in which personal information you provide to us is used and kept secure by Copper. It applies whenever we collect your personal data (including when you use our website or other digital platforms), so please read it carefully.

What is personal information

“Personal information” is anything which enables us to identify you in some way such as a name, email address, or an online identifier such as an IP address or that we can link to you. You may be asked to provide personal information through our digital channels such as the website. Special category data means personal information revealing your racial or ethnic origin; political opinions; religious or philosophical beliefs; or trade union membership; genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings.

Updating your personal information

If you need to change or amend your personal information, including your contact details, please notify Copper as soon as possible in writing or email; details can be found below.

Third party links

Please note that our website may contain links to third party websites / digital platforms which are provided for your convenience.

We are only responsible for the privacy practices and security of our own website.

We recommend that you check the privacy and security policies and procedures of each and every other website / digital platform that you visit.

The information that we collect

Information that you provide to us

  1. We will process personal information that you give to us including when you email us or contact us through various channels as follows:
  2. Signing up for services on our website: when you sign up for newsletters, webinars, events or digital asset acquisition or storage services from us or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
  3. In connection with our provision of digital asset acquisition and storage services: if you are a client of Copper you will provide us with personal information when you or the company you represent becomes a client. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.
  4. Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application

Information we obtain from other sources

  • If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
  • If we collect or receive your personal information in the context of our provision of digital asset acquisition and storage services we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities including law enforcement agencies. That information could include your name, contact details, employment details and other information relevant to the digital asset acquisition and storage services that we are providing to our client.

How we use the information we collect

We may do the following with your personal information:
  1. use it to provide digital asset acquisition and storage services to the relevant client;
  2. use it to engage in marketing and business development activity in relation to our services. This may include sending you newsletters, marketing communications and other information that may be of interest to you;
  3. where you have applied for a position with us, to review and process your job application;
  4. to comply with legal and regulatory obligations that we have to discharge;
  5. use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  6. record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
  7. use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business;
  8. use it to look into any complaints or queries you may have; and
  9. use it to prevent and respond to actual or potential fraud or illegal activities.

Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information:
  1. Consent – we may need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
  2. Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
  3. Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above.
  4. Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation including the:
    • Data Protection Act 2018;
    • General Data Protection Regulation (EU) 2016/679;
    • Money Laundering Regulations 2017;
    • Sanctions and Anti Money Laundering Act 2018; and
    • Currency and Foreign Transactions Reporting Act 1970 (Bank Secrecy Act) (for US clients only).

How we share information with third parties

We will not sell, trade or lease your personal information to others.

We share personal information with our international offices and the various companies and entities that make up our international network. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.

We may also share your personal information outside of Copper. We contract with third party service providers and suppliers to deliver certain services. Copper adheres to the requirement to have Data Processing Agreements in place with each of its providers so that they process your personal data in accordance with this Policy. This may include:

  1. Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
  2. Third parties relevant to the digital asset acquisition and storage services that we provide. This may include, but is not limited to, counterparties to transactions, other professional service providers, regulators, authorities, governmental institutions and exchanges.
  3. To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
The following third parties may also have access to your personal information:
  1. any other person who is authorised to act on your behalf;
  2. regulators, government departments, law enforcement authorities, tax authorities and insurance companies;
  3. any relevant dispute resolution body or the courts; and
  4. persons or businesses in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business.

Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:

  1. the country to which we send the personal information has an adequacy regulation in place with the UK;
  2. we have Standard Contractual Clauses approved by the UK ICO in place with the recipient, obliging them to protect your information;
  3. the recipient has Binding Corporate Rules; or
  4. the contractual clauses used are authorised by the UK ICO.

In other circumstances, the law may permit us to otherwise transfer your personal information outside the EEA. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.

You can obtain more details of the protection given to your personal information when it is transferred outside of the EEA by contacting us using the details set out below.

Keeping your information and information security

How long we hold your personal information for will vary and will depend principally on:

  1. the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
  2. legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.

We will not hold your personal information for any longer than is necessary, unless we are required to keep your personal data longer to comply with the law and any regulatory requirements.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Your choices and rights

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.

Your rights include:
  1. The right to access the personal information held about the you by making a subject access request in accordance with the data protection legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive;
    • Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
  2. The right to have your personal information rectified if it is inaccurate or incomplete;
  3. The right to request to have your personal information deleted in certain specific circumstances as set out in the data protection legislation;
    • Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
  4. The right to request to restrict the processing of your personal information in certain specific circumstances as set out in the data protection legislation;
    • Please note there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
  5. The right to ask us not to process your personal data for marketing purposes or for purposes based on our legitimate interests (in certain circumstances as set out in the data protection legislation);
  6. In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
  7. The right to ask us to not undergo automated decision making; and
  8. Where you have provided consent, to request to withdraw such consent at any time.
  9. In certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

There are some exemptions to the above rights that are permitted under the data protection legislation. If you have any queries as to what these are then please get in touch.

Please note that if you choose to exercise your rights to have personal data restricted or deleted, then we may not be able to provide you with a full service.

Further details about your rights can be found on the ICO’s website at https://ico.org.uk/

We will need you to provide identification in order to comply with your request to exercise your rights. Once we have received your information request, and your identification, we will respond within the required timescales unless a permitted exemption applies.

Cookies

In common with many other website operators, we use standard technology called 'cookies' on our website. Cookies are small pieces of information that are stored by your browser on your computer's hard drive and they are used to record how you navigate this website on each visit.

We will also collect information about when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our websites, such as Google Analytics. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites. For information about how we use Cookies and the choices you may have, please see our Cookies Policy.

Click here for information on our Cookies Policy

How to contact us and other important information

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us by writing to us at:

  • Email dpo@copper.co
  • Post Data Protection Officer, Copper Technologies (UK) Ltd, 64 North Row,
    3rd Floor, London, W1K 7DA.

If you would like to make a subject to access request in relation to the personal data that we hold for you, please contact us by writing to us at:

  • Email sars@copper.co
  • Post Data Protection Officer, Copper Technologies (UK) Ltd, 64 North Row,
    3rd Floor, London, W1K 7DA.

If you are not satisfied with the response you receive from us or how we handle your personal information, then you may wish to contact the Information Commissioner’s Office via https://ico.org.uk/.

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