GDPR Privacy Notice

This GDPR privacy notice sets forth how CF Global Trading, LLC (“CFGT”) and its wholly owned affiliates: CF Global Trading (UK) Ltd (‘’CFUK”) and CF Global (HK) Ltd (“CFHK”) collectively (‘CF Global Trading’, ‘us’, ‘we’, ‘our’, or ‘the firm’) complies with Regulation (EU) 2016/679, the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 when processing personal data.

This privacy notice is intended to help you understand our responsibilities in collecting and using your personal data in compliance with data protection law and your rights in connection with such collection and use. This policy applies to all personal data we process (wholly or partly) regardless of whether data is stored electronically, on paper, or on any other media. It applies to any personal data processing operations and must be complied with by:

• CF Global Trading (the Data Controller)
• All staff of CF Global Trading
• All contractors working for or on behalf of CF Global Trading

What types of Personal Data do we collect?

Personal data is ‘any information relating to an identified or identifiable natural person’ (the data subject). It does not include data where the identity of the natural person has been removed in such a manner that the data subject is not or no longer identifiable (anonymous data).

Using our data inventory, we have identified that we process personal data relating to the following:

• Client KYC information about the entity we contract with such as:
  • Registered name, address, telephone number and email address
  • Corporate documentation
  • Tax identification number
• Client KYC information about certain beneficial owners and other individuals of the client:
  • personal identification information such as name, address, email, telephone number
  • personal identification number, passports and other government issued
• Financial information to understand your financial profile and the origin of funds
• Transaction data related to the services we provide you
• Custodial bank details for the processing of your transactions with us
• Data relating to our telephone, video chats, electronic correspondence(s) (emails, Bloomberg messaging and chats), including information we retain about your interactions on our website and other social media platforms
• Information you provide regarding marketing data preferences

In addition to the personal data mentioned above the CF Global Trading Website uses a range of cookies to improve and personalize your experience. More information about these can be found in our Cookies Policy Cookie Notice | CF Global Trading

How do we collect your Personal Data?

We collect and process your Personal Data:

• When you open your brokerage account with us and with our clearing firm, RBC Capital Markets, LLC
• When we provide you with execution and administrative services
• When you use or view our website via your browser’s cookies

When you provide us with your marketing data preferences or respond to our marketing campaigns

What are the legal grounds and purposes for processing your Personal Data?

Your Personal Data may be processed by CF Global Trading for a variety of purposes:

• to open your account or any other agreement relating to provision of brokerage services with you
• to conduct necessary KYC as appropriate in the on-boarding process
• to perform anti-money laundering checks on your account and transactions on an ongoing basis
• to comply with any clauses in the terms of business or any other agreement relating to provision of brokerage services concluded with you
• to open accounts at CF Global Trading’s clearing brokers RBC Capital Markets, LLC or Global Prime Partners Limited, for the sole purpose of settling trades on a DVP/RVP basis
• to record transactions arising from agreements on the provision of brokerage services
• to accept, review and respond to your complaints, if any, regarding CF Global Trading’s activities
• to perform the obligations imposed on the data controller by the provisions of the generally applicable law or regulation such as transaction reporting or audit and regulator enquiries, or where CF Global are obliged to submit notifications such as a Suspicious Activity Report to the National Crime Agency or other relevant body
• to perform IT management, including infrastructure management (e.g. Shared platforms), business continuity and IT security
• to enable restricted members of staff representing CF Global Trading to have access to data to allow us to involve the right level of expertise to deal with your requests
• to process personal staff data to comply with our legal obligation to disclose employee salary details to the relevant governmental tax office
• for the purposes of processing invoices relating to the services we provide

We base the processing of your Personal Data to provide the services contracted with You, to comply with a legal obligation or for the purposes of our legitimate interests or in specific cases when you give us consent. Therefore, we base our data processing activities on the following lawful grounds:

1. Consent: when we have obtained your prior and express consent – in writing, orally or through the validation of an option – and such consent is freely given, informed, specific and unambiguous.
2. Performance of a contract or pre-contractual procedures: whenever the processing of personal data is necessary for the conclusion, performance or management of an agreement entered into with CF Global Trading, such as for the management of contacts/claims, invoicing/billing/payments;
3. Compliance with a legal obligation: whenever the processing of personal data is necessary to fulfil a legal obligation to which CF Global Trading is subject to, such as reporting to administrative, judicial and/or law enforcement agencies;
4. Legitimate interest: whenever the processing of personal data is necessary to safeguard a legitimate interest of CF Global Trading or of third parties, such as the improvement of the quality of the service or the detection of fraud.

Disclosure of your personal data to third parties:

From time to time, we may be required to disclose your personal data to third parties which may include:

• Our current affiliates: CF Global Trading (UK) Ltd and CF Global (HK) Ltd
• Other service providers, broker dealers and members of Exchanges
• Third party service providers
• Our clearing firm(s)
• Courts, regulatory bodies, tax, and governmental authorities

How do we store and secure your Personal Data?

We securely store your data by various methods and redundancies.

We limit access to your personal and account information to those employees who need to process such information for us to provide you with our contracted services.

We will not save your personal data for a longer period than is necessary to fulfill the purpose for which your data was collected and fulfill our legal requirements.

How long will your data be stored?

We will keep your personal information for as long as we maintain our business relationship, unless a different legal retention term applies. Following termination of our business relationship we will maintain your data in compliance with our legal and regulatory obligations.

We will not retain any personal data for longer than the time necessary for satisfying the purposes of its processing, subject to the general statutory limitation periods and above-mentioned retention period, where the applicable laws requires that the personal data is retained for a certain period after the termination of our business relationship with you.

At the expiration of the data retention period the data is erased by irreversible destruction and/or is anonymised.

What are your Personal Data protection rights?

• Right of Access: You have the right to request access to your collected Personal Data
• Right of Rectification: You have the right to request that we correct any information you believe to be inaccurate or to complete information you believe is incomplete.
• Right of Erasure: You have the right to request that we erase your personal data, under certain conditions, provided we comply with all rules and regulations we are required to do so by law.
• Right to Restrict Processing: You have the right to object to CF Global Trading’s processing of your personal data, under certain conditions.
• Right to Data Portability: You have the right to request that we transfer the data that we collect to another organization, or directly to you under certain conditions.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, which can be extended under certain conditions provided by the law.

Changes to our GDPR Privacy Policy

We regularly review our GDPR privacy policy and place any updates on our website www.cfglobal.com. Therefore, we invite you to regularly check those updates. This policy notice was last updated on January 25, 2023.

How to complain

If you have a concern about any aspect of our privacy practices, you can make a complaint. We will act promptly against any complaints.

To make a complaint, please contact us using the details below. You can also directly contact our Data Protection Officer at hb@cfglobal.com. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. If you are resident in the EU, you may also lodge a complaint with the EU Supervisory Authority, in particular in the Member State of your habitual residence, place of work or place of alleged infringement if you consider that the processing of personal data in question infringes the GDPR.

How to contact us

If you would like to exercise any of these rights, or if you would like to obtain further information about how we process your personal data, please contact us by using any of the following:

• Email: privacy@cfglobal.com
• Telephone: (212) 888-4711
• Mail: Compliance Department

60 East 42^nd Street, Suite 1455 New York, NY 10165

Learn more about our personal data processing through our UK Data Protection Policy | CF Global Trading.