(Last Updated 17th March 2021)
Privacy Policy
Introduction
We are Obermind Ltd (“Obermind”, “us”,”our” or “we”). We provide a platform and services with access to data, execution, management, visualisation and automation for financial markets (“Platform”). You can find out more about who we are and what we do on obermind.com. This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing the Platform. This policy also provides contact details and important information about data protection rights. This policy was last updated March 2021. We will periodically update this policy so please check back for updates.
What personal data do we collect?
Platform users
We collect personal data relating to individuals who use our Platform. This includes individuals who have their own accounts with Obermind and individuals who access our Platform as end-users, employees, agents, representatives or officers of our customers.
The information we collect comes directly from Platform users and, where applicable, our customers. It includes:
- Product purchase, order and payment information
- Profile data (including login details, Platform usage, interests, preferences, survey responses and feedback)
- Contact details (including telephone number and email address)
- Device information (including browser type, plugins,operating system, time zone setting and location, ID, IP address)
- Relevant Software and/or API usage information (including number of calls, subscriptions, messaging, order/portfolio data, service providers)
- Marketing and communications data (including preferences)
- Cookie data (please see cookie section below)
Website users
The information we collect from people who visit obermind.com includes:
- IP address
- Website usage
- Cookie date (please see cookie section below)
- Personal data entered to webforms
People we work with
We collect personal data directly from individuals we work with. We collect personal data from their employers or the organisations they represent. We also collect personal data relating to people we work with from other organisations we work with (for example, industry conferences, media, social media, other platforms and industry partners). The personal data we collect relating to people we work with includes:
- Name
- Address
- Contact details (including telephone and email)
- Social media
- Professional and employment details
- Personal data in correspondence
- CCTV
- Visitor details
How we use personal data
Platform users
We use the personal data relating to Platform users to:
- Provide. develop and promote the Platform
- Improve the Platform by providing personalised content, language, help and instructions
- Customize the Platform by location
- Provide customer service assistance
- Ask people to participate in surveys, products, services, news and events
- Better understand how the Platform is used (including checking traffic patterns and what types of content are most popular)
- Receive and respond to correspondence
- Exercise legal rights and comply with legal obligations
Website users
We use personal data relating to users of our websites mainly to provide, develop and promote our websites, Platform and wider business. More specifically, we use personal data relating to website users to:
- Provide customer service assistance
- Better understand how our websites are used (including checking traffic patterns and what types of content are most popular)
- Website analytics and improvements
- Detect and address security risks
- Detect fraud and other unlawful activity
- Exercise legal rights and comply with legal obligations
People we work with
We use personal data relating to people we work with mainly to provide, develop and promote our Platform and wider business. More specifically, we use personal data relating to people we work with to:
- Mange orders to suppliers and from customers
- Arrange events
- Manage business and professional relationships
- Detect and address security risks
- Detect fraud and other unlawful activity
- Exercise legal rights and comply with legal obligations
Our legal grounds to use personal data
Platform users
Contract
If we have a contract with a Platform user, we will use personal data relating to them where necessary for the performance of that contract.
Legitimate interests
We will also use personal data relating to Platform users where necessary for the purposes of legitimate interests pursued by Obermind and our customers. This includes using personal data relating to an employee, agent, representative or officer of a customer for the purposes of administering the customer’s account and providing the Platform. However, we will only use personal data relating to Platform users for the purposes of legitimate interests where Platform users’ interests and rights freedoms do not override our legitimate interests or the legitimate interests of our customers.
Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust market research, portfolio management and building enterprise-level financial applications.
We have carried out a legitimate interests assessment of our use of personal data relating to Platform users. We consider that the interests and rights and freedoms of Platform users do not override our legitimate interests and particularly do not override the compelling legitimate interests of our customers.
Consent
Our legal ground for sending Platform users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.
Website users
Legitimate interests
We will also use personal data relating to website users where necessary for the purposes of legitimate interests pursued by Obermind. We will only use personal data relating to website users for the purposes of legitimate interests where website users’ interests and rights freedoms do not override our legitimate interests or the legitimate interests of our customers.
Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust market research. We have carried out a legitimate interests assessment of our use of personal data relating to website users. We consider that the interests and rights and freedoms of website users do not override our legitimate interests or the legitimate interests of our customers.
Consent
Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.
People we work with
Legitimate interests
We use personal data relating to people we work with where necessary for the purposes of legitimate interests pursued by us. Our legitimate interests include for the purpose of providing, developing and promoting our Platform and wider business. We will only use personal data relating to the people we work with for the purposes of legitimate interests where their interests and rights freedoms do not override our legitimate interests.
Consent
Our legal ground for sending website users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.
Automated decision-making
We do not make any legally significant decisions about individuals based solely on automated decision-making.
Sharing personal data
Platform users
We share personal data relating to Platform users with their employers or the customer on whose behalf they are accessing the Platform, our staff and the following types of service providers:
- Payment processors
- Advertising partners (see cookies section below)
- Analytics service providers (see cookies section below)
- IT providers
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Obermind and/or the Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
Website users
We share personal data relating to website users with our staff and the following types of service providers:
- Advertising partners (see cookies section below)
- Analytics service providers (see cookies section below)
- IT providers
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Obermind and/or the Platform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
People we work with
We share personal data with our staff and the following types of service providers:
- E-commerce platforms
- Payment processors
- IT providers
- Marketing partners
- Group companies
- Business partners
- Professional service providers (for example, accountants and lawyers)
We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Obermind or ourPlatform. We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.
Cookies and similar technologies
Cookies are small information files that we place on the devices used to access obermind.com and the Platform. The types of Cookies we use are described below.
Essential cookies
Our website and Platform will not work properly without essential cookies. For example, we and our service providers may use essential cookies to identify and authenticate Platform users. We also use essential cookies to provide customer service (including tracking customer journey and analytics for support purposes), enforce our Terms and Conditions and maintain the security of our website and the Platform. The essential cookies we use on the Platform include :
- Heap
- New Relic
- Full Story
- Google / reCAPTCHA
The essential cookies we use on the website include:
- Google / reCAPTCHA
Non-essential performance or analytics cookies
Non-essential performance or analytics cookies collect information and analytics about how people use our website. For example, which pages users visit most often and error messages received by users from web pages. We always seek consent for the use of analytics cookies on the website. We do not use non-essential performance or analytics cookies on the Platform.
The analytics providers we use on the website include:
- Heap
- Pardot
- Hotjar
- Leadfeeder
Advertising cookies
Advertising cookies are used to deliver advertisements relevant to visitors based on the visitor’s interests and to measure the effectiveness of advertising campaigns.
These cookies are usually placed by advertising networks with our permission.
They remember that you have visited the website and this information is shared with other organisations such as advertisers. We always seek consent for advertising cookies on our website. We do not use advertising cookies on the Platform.
The advertisers we work with on the website include:
- Hotjar
- Pardot
Children
We do not knowingly collect or use any personal data relating to children.
International transfers
Where we transfer personal data outside the UK to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses or other appropriate safeguard or we will identify an appropriate exemption.
Data retention
Platform users
We keep personal data relating to Platform users for up to six years after the end of our agreement with them or their employer or the customer on whose behalf they are accessing the Platform.
Website users
We keep personal data relating to the website for as long as necessary for our business purposes.
Rights
Everyone has the right to:
- Information about how we use personal data (which is what this policy is for)
- Access to personal data
- Object to the use of personal data
- Erasure of personal data
- Portability of personal data
- Withdraw consent where our use of personal data is based on consent
- Rectification of personal data
- Restriction of personal data
- Complain to your supervisory authority
Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or they are not relevant. The Information Commissioner’s Office provides more information about data protection rights – www.ico.org.uk.
If you do not provide personal data
Where we need personal data for an agreement with you under our Terms and you do not provide that personal data, we may not be able to perform our agreement. In this case, we may have to cancel your access to the Platform.
Our contact and DPO details
Email us directly
Our registered office
64 Southwark Bridge Road
London SE1 0AS
United Kingdom
Website
https://obermind.com/
Data Protection Officer
If you would like to contact our Data Protection Officer (“DPO”), please email [email protected].