We’re committed to protecting and respecting your privacy.
We are Czarnikow Group Limited (“Czarnikow”, “we”, “our”, “us”) and we operate under the name of Czarnikow.
C. Czarnikow Sugar Futures Limited, a subsidiary of Czarnikow Group Limited, is a regulated entity with the FCA.
If you have any concerns about your privacy, please contact us by e-mailing us at email@example.com, or by writing to us at Paternoster House, 65 St. Paul's Churchyard, London, EC4M 8AB, United Kingdom.
We’re registered with the Information Commissioner’s Office under number ZA118371. C. Czarnikow Sugar Futures Limited is registered with the Information Commissioner’s Office under number ZA128187.
Scope of the policy
This policy together with the General Terms of Service and our Business Terms of Service and our Business Terms (as applicable) apply to your use of:
a) our website at czarnikow.com (the "Site")
b) any of the services available through Czarnikow and its subsidiaries
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
We are the data controller responsible for your personal data and we are registered with the Information Commissioner's Office with reference number ZA118371.
Information we collect about you
We will collect and process the following data about you:
- Information you give us "Submitted Information": This is information you give us about you by filling in forms on our Site, or by corresponding with us (for example, by e-mail or in person). It includes information you provide when you register to use the website, subscribe to any of our services, enter into any transaction, participate in discussion boards or other social media functions on the Site, respond to a survey and when you report a problem with our Services, or our Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, career information (in the case of employment applications), copies of identification documents (for example, passport, driving licence) personal description and photograph and any other information you provide us in order to facilitate the use of our services.
- Information we collect about you and your device: Each time you visit our Site we will automatically collect the following information: (i) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information"; (ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
- Location Information: We use your IP address to determine your location when you access our website.
- Information to help us deliver our service to you: We work closely with third parties in order to help us deliver our Services to you. These third parties are business partners, sub-contractors in technical, financial and operational services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers, Recruitment agencies, and developers. Information we may collect about you from such parties can include information which helps us to verify your identity or information relating to your transactions or interactions with us.
How we will use this information and what we will not do
We will use the data we collect from you for the following purposes:
- Help manage services and transactions we deliver to you and your organisation;
- Track, analyse and improve the services we provide you and other customers;
- To resolve technical issues you encounter, to respond to requests for assistance, to analyse crash information, and to repair and improve our Services.
- To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
- Market and communicate our market information, products and services and those of affiliated partners where we think these will be of interest to you. You can always unsubscribe from receiving these if you want to, by the link provided in our e-mails;
- Contact you directly with information about services which we believe will be of interest to you and your organisation;
- To administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer;
- This is also only relevant for when the new portal goes live
- To notify you about changes to our service; and As part of our efforts to keep our Site and the App safe and secure;
- Deliver internal training to improve the quality of service we provide;
- To assess suitability for a role
- To process requests for products and services available through us including making decisions about whether to agree to approve any business transaction.
We will not do the following with your information:
- We won’t share identifiable personal data with unrelated third parties for their direct marketing unless you give us permission
- We will only keep your personal information for only as long as we need to. We’ll then delete it securely and safely
- There may be times when you give us sensitive information such as your racial origin or trade union membership. We’ll only use this information in strict accordance with the law
With whom do we share your information?
In addition to using your data internally, we will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us. We will ensure that they use this data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Czarnikow.
We send personal data to the following sets of data processors in order to perform our Services:
- Fraud prevention agencies. This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
- Cloud storage providers. This is in order to safely and securely store your data with Czarnikow;
- Service partners. Third party providers that help us provide our Services including, but not limited to, banking partners, banking intermediaries, international payments services providers, logistics providers, producers and consumers of the products traded;
- Advertisers and analytics providers. If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We also use analytics and search engine providers that assist us in the improvement and optimisation of our site, and our data (for example, scanning for contact details which are no longer active and can be deleted);
- Subsidiaries of Czarnikow Group Limited. In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of Czarnikow Group Limited, which means any of our subsidiaries or related entities. For example, we may share your data with C. Czarnikow Sugar Futures Limited, an FCA authorised and regulated subsidiary of Czarnikow. A data transfer agreement exists between these entities to control how we manage your data.
- We would also share your information in the following circumstances: If Czarnikow is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to: (i) enforce or apply any agreements between you and us or to investigate potential breaches; or (ii) protect the rights, property or safety of Czarnikow, our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- We will also share your data with any organisation you give us explicit permission to share it with
THIRD PARTY SERVICES PARTNERS
- From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties.
You can withdraw your consent at any time after giving your explicit opt-in consent by contacting us via the contact details listed below.
Storage security and international transfers
The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (EEA). As we provide an international service your data may be processed outside of the EEA in order for us to fulfil our contract with you to provide our Services. All such data transfers are managed under relevant data transfer agreements.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long will we keep your information?
As an FCA authorised firm, and in order to comply with relevant regulations, C. Czarnikow Sugar Futures Limited may need to hold your data for a period of up to 6 years. We will not hold any of your personal data for more than 6 years after the termination of our business relationship.
Your legal rights
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our team via the contact details listed below.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our team via the contact details listed below.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. As an FCA authorised firm, C. Czarnikow Sugar Furtures Limited is under certain obligations to retain certain data for a minimum of 6 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
- Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. As an FCA authorised firm, C. Czarnikow Sugar Futures Limited is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide our Services.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the our Services). In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time.
- Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via the in-App chat function.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our Services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate access requests within a month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, but we will notify you if this is the case at the time.
Any material changes we make to our privacy notice in the future will be posted on this page and, if appropriate, sent to you by email. We may require you to read and accept these new terms in order to continue using our services.
Address: Legal and Compliance, Paternoster House, 65 St. Paul's Churchyard, London, EC4M 8AB, United Kingdom.
Tel: +44 (0) 20 7972 6600