GDPR

Privacy Policy – EU
Last updated: June 1, 2021

PRIVACY POLICY FOR EUROPEAN UNION

GENERAL

Hammerstone Markets Inc. (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at www.thehammerstone.com, and www.hammerstonemarkets.com including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website.

The Hammerstone digital platform (the “Platform”) is accessible through Hammerstone’s websites (including www.thehammerstone.com),and www.hammerstonemarkets.com any smartphone applications, tablet applications, and Hammerstone’s other network-connected products and services that link to these Terms of Use, as well as by and through Hammerstone emails and social media pages. The following terms and conditions (“Terms”) govern the use of the Platform by you or your company (hereinafter referred to as “you”).

This document shall apply when you use the Website or any services covered by the Privacy Policy from a country that is a Member State of the European Union.

This document supplements information in the Privacy Policy. It is neither intended to override the terms of any contract you have with us, nor any rights you might have under data protection laws.

Please note that the Website is not intended for anyone under 18 years of age. We do not intentionally collect or use any information from children.

Legal bases for processing your personal data
We process your personal data for the purposes set out in this section and where we are satisfied that:

• you have provided your consent to us using the data in that way, or
• our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to send you communications if we think appropriate to inform you about similar products or services, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy; or
• Contract – for example if you have a subscription and in order to handle invoicing, payments or refunds; or
• Legal requirement – for example when necessary to comply with accounting rules or mandatory disclosure to law enforcement

How long do we keep your personal data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 1. We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.

Cookies
You can generally view the Website without cookies, but certain parts of the website may not work properly or navigating be slower.

If you do not wish cookies to be stored on your computer or device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

More information on how to deactivate or delete cookies can be found here: https://www.aboutcookies.org/cookie-faq/. However, please keep in mind that if you do not accept any cookies this may restrict the functionality of our offerings.

What are your rights?
You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.

To privacy@hammerstonemarkets.com or by letter to Hammerstone Markets, Inc. c/o Data protection officer, 79 Old Ridgefield Road, Wilton CT 06897

Right What this means
Access You can ask us to:
– confirm whether we are processing your personal data;
– give you a copy of that data;
– provide you with other information about your personal data, for example what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.
Rectification You can ask us to rectify inaccurate personal data.
We may seek to verify the accuracy of the data before rectifying it.

Erasure You can ask us to erase your personal data, but only where:
– it is no longer needed for the purposes for which it was collected; or
– you have withdrawn your consent (where processing was based on consent); or
– following a successful right to object (see ‘Objection’ below); or
– it has been processed unlawfully; or
– to comply with a legal obligation.
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:

– for compliance with a legal obligation; or
– for the establishment, exercise or defence of legal claims;
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request

Restriction
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
– its accuracy is contested (see Rectification), to allow us to verify its accuracy; or
– the processing is unlawful, but you do not want it erased; or
– it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
– you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

– we have your consent; or
– to establish, exercise or defend legal claims; or
– to protect the rights of another natural or legal person.
Portability You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another Data Controller, but in each case only where:
– the processing is based on your consent or on the performance of a contract with you; and
– the processing is carried out by automated means.
Objection You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Supervisory Authority You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.