This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize Zagzig's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about Zagzig's privacy policies that may be applicable to them.
This Policy is specifically addressed to those who provide Personal Information to Zagzig or who visit or use Zagzig's websites, trading platforms, software application and social media sites.
Zagzig is responsible for the Personal Information that we may collect in the manner discussed below. Specifically, your Personal Information will be controlled by the Zagzig company that is providing services or communication to you.
Zagzig collects and processes Personal Information from you. This may include, among other things, information:
In order for you to utilize our services, you will provide us with your Personal Information entirely voluntarily. In most circumstances Zagzig cannot take action without utilizing certain of your Personal Information, for example, because this Personal Information is required to process your instructions or orders or provide you with access to our services or marketing materials. In most cases, it will be impossible for us to provide the services to you without the relevant Personal Information.
We may use your Personal Information for the following purposes ("Permitted Purposes"):
We may process your Personal Information for the following purposes after obtaining your express consent where legally required:
Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:
We may share your Personal Information between the Zagzig Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which Zagzig Entities are located can be found on our website;
We may instruct service providers within or outside of Zagzig, domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions. For example, if you choose to subscribe to any services provided by a third-party provider listed on an Zagzig Investors' Marketplace, we may disclose such information to the service providers as necessary for them to provide the services that you have requested. Zagzig generally requires these service providers to enter into confidentiality agreements with Zagzig that limit their use of the information that they receive.
Such agreements prohibit the service provider from using Zagzig client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, Zagzig will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
We may share your data with third parties to assist us with the conduct of our recruitment processes;
Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Personal Information about other people that you provide to us
To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.
For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") we may transfer your Personal Information outside the EEA for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.
With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the EEA that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.
If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting Zagzig Client Service through the Zagzig website at interactivebrokers.com/help. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.
How long do we retain your Personal Information?
We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.
With respect to EEA residents and where your Personal Information is processed by an Zagzig Entity established in the EEA ("Covered Individuals"), you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include:
Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. 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);
Requesting that we correct your personal information if it is inaccurate or incomplete;
Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, 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;
Withdrawing your consent, although 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.
We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us.
We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.
Notice to California Residents: As a federally-regulated provider of financial services, Zagzig is broadly exempt from the California Consumer Privacy Act (CCPA). Personal information we collect from clients and prospective clients is protected under separate federal legislation. Over the past 12 months, the only type of information we have collected potentially subject to the CCPA is web-browsing information regarding passive visitors to our website who are California residents, but are not our clients and do not provide us with any specific personal information (name, email address, street address, social security number, etc.) to request information about our services, start an account application, or become a client. Information collected from these anonymous, passive visitors to our website may include IP address and browser-specific tags. We do not sell this information to third parties. We only use this information for internal purposes, such as to determine which advertisements are working and which content on our website is most interesting to visitors. Under the CCPA, California residents connected to this type of web-browsing data have a right to request access to it or request that it be deleted. However, we are unable (and not required) to process such requests because we cannot connect such passive web-browsing information collected with an email address or other personal information that we can use to verify that a requesting party is in fact connected to a specific web-browser or IP address.