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Privacy Policy

Privacy Policy

Contents

1. Scope

Radial Platforms, Inc. and its affiliates including Radial-X, LLC (referred to as the "Company", “we” or “us”) respect the privacy interests of visitors to this Website (this “Site”) and users of our products and services. Your privacy is important to us. This Privacy Statement describes the nature of that respect and commitment by detailing the types of the personal information that we collect, the uses we make of that information, and related information regarding your ability to access, correct, and request deletion of any personal identifying information you choose to give us.

By accessing this Site or using our products or services, you agree to be bound by the Privacy Statement. If you do not agree to the terms of this Privacy Statement, please do not use this Site or our products or services. As our business grows and changes, and as technology and Internet use and practices change, the Company may, from time to time, determine that changes in its policies, including this Privacy Statement, are prudent. Each time you use the Site or our products or services, the current version of the Privacy Statement will apply. Accordingly, when you access the Site or periodically when using our products or services, you should check the date of this Policy (which appears at the bottom) and review any changes since the last version.

This Privacy Statement should be read together with any other privacy notice or statement that we provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This Privacy Statement supplements the other notices but does not override them.

2. Personal Data We Collect About You

We will collect, use, store and transfer different categories of personal data about you as follows:

Identity Data

This includes your name and job title, and for certain Company services accessed by you in the European Union (EU), may also include your date of birth, nationality, and national ID (such as your passport number).

Professional Contact Data

This is the data that allows us to contact you, and includes your email address, postal address, and telephone number.

Technical Data

This includes your internet protocol (IP) address (which helps us to determine the location of the device you use to connect to our systems and to determine the number of devices simultaneously accessing the services), your username and password, and the information which we may obtain on your technical profile through our use of cookies on your browser.

Professional Profile Data

This is data that you or your organization may provide to us about your job role, function, and business focus.

Company Relationship Data

This is data we obtain from our interactions with you, includes details of any calls you have made to our staff or help desk, visits made to you by our staff, marketing materials you have received, your email communication with our staff, data about your preferred activities for marketing events or any Company events you have attended, and your preferences in receiving marketing communications from us.

Product or Subscription Usage Data

This is data we obtain about your usage of our products and services, including when and which products you have used, subscribed for, or are enabled to access, and the content and functionality you have used in those products and services.

Publicly Available Information

This includes data we obtain from directories, websites, public records, or media sources.

Personal Data collected from third parties

This is data we obtain from Company affiliates or third parties, including for example KYC (know-your-client) information regarding your employment status and the results of any regulatory screening processes, and could also include conference lists and financial services directories.

Referrals

This is data we obtain from other Radial companies or through our website or other Radial clients.

3. Purposes for which we will use Personal Data

We process personal data for the following purposes:

Account setup and administration

We use personal data in order to set up your access to a product or service that you have subscribed for and to manage invoicing and payments.

Provision of service

We use the personal data we collect about you to provide you with our products and services and to assist you in your use of these. This includes providing any necessary operational assistance, support, and training, and alerting you to product changes or maintenance periods.

Sales and marketing

We will from time to time use the personal data we collect about you to contact you by e-mail, post, or telephone with information about the Company, the products and services you use, other Company products and services similar to those you use and events that might be of interest to you or your organization. If you submit an enquiry to us on our website or make an enquiry in person at an event, then we will use the personal data that you provide to us to respond to your enquiry, and to contact you about any products or services that you confirm to us that you are interested in hearing about. You may ask us to refrain from sending you marketing messages at any time as described in the "Your Choices" section of this Privacy Statement.

If you are located in Canada, the Company relies on implied consent for the purposes of Canada’s Anti-Spam Law and the scope of the recipients’ role(s) and responsibilities with their company. At any time, recipients may opt-out of marketing communications from Radial as described in the “Your Choices” section below or by clicking the Unsubscribe link in the message.

Product development and improvement

We may occasionally use the personal data we collect about you to ask you to participate in surveys and questionnaires to improve, customize and enhance our products and services. In addition, we reserve the right to use the data, combined in aggregate form with the personal data we have collected about other users of our professional financial and media products, for statistical purposes, or to plan and implement developments of, and enhancements to, our products and product range.

Compliance checks and regulatory record-keeping

We also use personal data to conduct know-your-client (KYC) and other compliance checks on our clients and conduct system monitoring and surveillance which the Company is required by law and regulation to carry out. We will also need to retain certain personal data for regulatory record-keeping purposes.

Please see the European Specific Legal Disclosures section for the legal basis on which we process the personal data of individuals based in the EU.

4. Sharing Personal Data

Except as described in this Privacy Statement, the Company will not sell our contact list or provide your personal identifying information to any non-affiliated person or entity in the ordinary course of our business, although the Company expressly reserves the right to transfer such information in connection with a change in ownership of the Company or its assets.

Radial Platforms companies

We share personal data with other companies within the Company acting as joint controllers who are based in the United States, Europe, and Australia in order to provide operational and system administration services.

Your employer

We will provide your employer with reports containing the product usage data of its employees.

Third party providers of content

We may share personal data with third-party content providers that you have subscribed to where it is necessary for them to confirm that a user is entitled to access their content and to evaluate and manage how that content is used in our services.

Third Parties

We use other companies as data processors to process certain personal data on our behalf, including service providers who may have access to your personal data in order to assist us in our administration of the services. For example, we use:

  • - customer relationship management software providers, such as Hubspot, in order to assist with the provision of our services and to contact you;
  • - KYC, surveillance, and regulatory screening providers who assist us with meeting our compliance obligations, such as Eventus

Third parties that have access to personal data are required by us and by applicable law to protect it in a manner consistent with this Privacy Statement.

Professional Advisers

Our professional advisers including lawyers, auditors and insurers could have access to your personal data during the course of the performance of their professional services to us.

Disclosure for Legal Purposes

We will provide access to your personal data when legally required to do so including, without limitation, to cooperate with regulatory and other government investigations or other legal proceedings.

Third party recipients of your personal data are only permitted to use it for the purposes of performing services on our behalf and in accordance with our instructions. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws.

We may disclose or transfer any information we have about you to third parties in connection with any sale, transfer or merger of all or a portion of our business or assets. Should such a sale, transfer or merger occur, the transferee(s) may use information you have provided in a manner that is consistent with this Privacy Statement.

5. Transfer of Personal Data to Other Countries

The Company is a global operation, we reserve the right to share personal data within the Company which may involve transferring it to different countries, including the United States, Europe, and Australia.

If you are located in the EU, your personal data will be transferred on the basis set out in section 6 below.

6. European Specific Legal Disclosures

Legal Basis for Processing

If you are located in the EU, the below legal bases apply to the Company’s processing of the personal data that you provide to us. Note that we process personal data on more than one lawful ground depending on the specific purposes for which we are using personal data.

Purpose for processing Type of data Lawful basis for processing
Account set up and administration
  • - Identity data
  • - Professional contact data
  • - Technical data
  • - Relationship data
  • - Professional Profile Data
  • - Personal Data collected from third parties
  • - Referrals
  • - Performance of a contract with you
  • - Necessary to comply with a legal obligation
  • - Consent
Provision of service
  • - Identity data
  • - Professional contact data
  • - Technical data
  • - Professional Profile Data
  • - Relationship Data
  • - Product or subscription usage data
  • - Performance of a contract with you
  • - Consent
Sales and marketing
  • - Identity data
  • - Professional contact data
  • - Technical data
  • - Professional profile data
  • - Relationship data
  • - Product or subscription usage data
  • - Publicly available information
  • - Personal Data collected from third parties
  • - Referrals
  • - Surveys, competitions and prize draws
  • - Necessary for our legitimate interests (to develop our products/services and grow our business)
  • - Consent
Product development and improvement
  • - Identity data
  • - Professional contact data
  • - Technical data
  • - Professional profile data
  • - Product or subscription usage data
  • - Data collected from third parties
  • - Surveys, competitions and prize draws
  • - Performance of a contract with you
  • - Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Compliance checks and regulatory record-keeping
  • - Identity Data
  • - Professional Contact Data
  • - Technical Data
  • - Professional Profile Data
  • - Relationship Data
  • - Product or subscription usage data
  • - Personal data collected from third parties
  • - Necessary to comply with a legal obligation
Transfers of personal data outside of the EU

If you are located in the EU, the personal data that we collect from you will be transferred to and processed in the United States, and Australia by the Company, and may also be held on servers globally by some of our service providers, for example Hubspot in Australia and other global locations. We ensure that any personal data which is transferred by us outside of the EU is appropriately safeguarded by using either of the following legal mechanisms:

The transfers of personal data are based on the European Commission’s model contracts for the transfer of the personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU.

The transfer is to a country that has been designated as providing an adequate level of protection for personal data by the European Commission.

For further information on our legal safeguard mechanisms used when transferring personal data outside of the EU, please contact us at privacy@radial-x.com

Your legal rights if based in the EU

You have certain rights afforded to you under European data protection laws in relation to our processing of your personal data if you are based in the EU:

  • - Access: the right to request access to your personal data and to find out how we use it and who it is shared with.
  • - Correction: the right to request correction of the personal data that we hold about you or to have incomplete personal data completed.
  • - Erasure: the right to request that we erase the personal data that we hold about you in certain circumstances prescribed by EU law. Your request for erasure will be balanced against our legitimate requirements to process your personal data, including our regulatory record-keeping requirements.
  • - Restriction: the right to require us to restrict our processing of your personal data in certain circumstances prescribed by EU law. Your request for restriction will be balanced against our legitimate requirements to process your personal data.
  • - Objection: the right to object to our processing of your personal data where we are relying on a legitimate interest and your specific situation means that you wish to object to processing on this ground as you feel that it impacts your fundamental rights and freedoms. You may also object to our processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms.
  • - Portability: the right to receive the personal data that we collect from you in a structured, commonly used and machine-readable format, and the right to request that we transfer such personal data to another party.
  • - Withdraw consent: where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time.

Contact details for EU data requests and complaints

With respect to the personal data that is processed within the UK and the rest of the EU, Radial Platforms, Inc. is responsible for processing personal data and are the “controllers” for your personal data when you subscribe to a product or service in the EU. You may at any time submit a personal data query, a request to exercise any of your above rights, or a complaint by contacting us by email at:

Radial Platforms, Inc.

Email: privacy@radial-x.com

We aim to respond to all legitimate requests within one month, except where your request is particularly complex or you have made a number of requests, in which case we may take longer to respond to you but will in any case notify you of this and keep you updated accordingly.

Note that you also have the right under EU data protection laws to make a complaint at any time to the applicable supervisory authority, which in the UK is the Information Commissioner’s Office (ICO).

Data retention period

In the EU, we are required by law to retain certain information about our customers (including contact, identity, financial and transaction data) for a minimum of five years after they cease being customers for regulatory and tax purposes.

We will retain personal data if it is anonymized (i.e. so that you are no longer identifiable) for statistical and research purposes for an indefinite period of time without further notice.

7. Security

The Company uses efforts consistent with sound industry practice, such as firewalls and encryption, to safeguard the confidentiality of your personal identifying information.

Given the nature of the Internet, however, the Company cannot and does not ensure complete security. The Company shall not be responsible for any breach of security or for the actions of any other person or entity.

Hackers pose a threat to any Internet user, and the legal and regulatory status of matters on the Internet is uncertain both in the United States and abroad. For these reasons, the Company cannot and does not guarantee that all of your personal identifying information will never be disclosed in ways you do not expect, or which are not described in this Privacy Statement.

We will make commercially reasonable efforts to see that your information is treated in compliance with this Privacy Statement.

IN NO EVENT WILL THE COMPANY OR OUR OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, AGENTS, LICENSORS, SUPPLIERS OR ANY PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THIS SITE BE LIABLE IN ANY MANNER WHATSOEVER FOR ANY DAMAGES OF ANY KIND, INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES ARISING OUT OF: (I) OUR WEBSITE, YOUR ACCESS, USE OR INABILITY TO USE OUR WEBSITE; (ii) ANY FAILURE OR PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE (INCLUDING LOSS PROFITS, LOSS OF BUSINESS OR DATA, BUSINESS INTERRUPTION, AND DAMAGES THAT RESULT FROM INACCURACY OF THE INFORMATION OR INCONVENIENCE, DELAY, OR LOSS OF THE USE OF OUR WEBSITE); (III) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF OUR WEBSITE, (IV) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL IDENTIFIABLE INFORMATION STORED THEREIN, (V) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR THROUGH THE SITE BY ANY THIRD PARTY. THE FOREGOING LIMITATIONS APPLY WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE STRICT LIABILITY OR ANY OTHER BASIS, EVEN IF WE OR OUR AFFILIATES OR ANY OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

8. Your Choices

You may contact us to access the personal data you provide to us and to ask us to update, correct, or delete it from our databases, where it is legally permissible for us to do so. You may also request that we cease using your personal data for marketing purposes. If you do not wish to receive marketing emails and /or marketing materials from the Company about the products and services we provide, or if any of your contact details are incorrect, please let us know by emailing us at:

Email: privacy@radial-x.com

Or by clicking the Unsubscribe link found in the marketing communications.

9. Children

Children under 18 should not send any information about themselves to us, including information like your name, address or e-mail address. The Company does not knowingly collect personally identifying information from children under the age of 18. In the event that we learn that we have collected such information from a child under 18, the information will be deleted from our database as soon as reasonably possible.

This Site may contain links to websites operated by other people or companies. Those websites may have their own privacy policy or no privacy policy at all. We do not have any responsibility for those websites, and we provide the links solely for the convenience of our visitors.

11. Changes to this Privacy Statement and your Duty to Inform Us of Changes

This Privacy Statement may be updated periodically. We will indicate below when it was most recently updated and inform you, in this Privacy Statement, through email and/or a notice on the Company website, of any significant changes.

Last updated: 17 October, 2023

It is important that the personal data that we hold about you is correct and up-to-date, so please notify us of any changes to your personal data during your relationship with us.