Contents
- Scope
- Personal Data We Collect About You
- Sources of Personal Data
- Purposes for which we collect and use Personal Data
- Disclosing Personal Data
- Transfer of Personal Data to Other Countries
- Storing and Retaining your personal information
- Security
- Cookies
- Changes to this Privacy Statement and your duty to inform us of changes
EU and UK Privacy Notice
- Personal Data We Collect
- European Specific Legal Disclosures
- Transfers of Personal Data outside of the EU or the UK
- Your legal rights if based in the EU or the UK
- Data retention period
- Contact Details
Australia Privacy Notice
- How we hold personal data
- Disclosing personal data outside Australia
- Your legal rights if based in Australia
- Contact details for Australian access requests and complaints
Privacy Notice for California Residents
- Information We Collect
- Use of Personal Information
- Disclosure of Personal Information
- Your Rights
- Exercising Your Right to Access, Correct, and Delete
- Authorized Agent
- Non-Discrimination
- Contact Details
1. Scope
Respecting your privacy is important to Tradeweb. This Privacy Statement is issued on behalf of the Tradeweb group of companies, so references to “Tradeweb”, “we”, “us” or “our” are references to the relevant company in the Tradeweb group responsible for processing your personal data (for the purposes of this Privacy Statement, personal data and personal information will be collectively referred to as personal data). This Privacy Statement describes the personal data that Tradeweb collects from you when you access any of our products or services, visit any Tradeweb website, contact us or request further information regarding a product or service. It also describes how your personal data is used and processed by Tradeweb and for what purposes we process it. This Privacy Statement should be read together with any other region specific privacy notices contained herein, and 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 collect, use, store, disclose, and transfer the following categories of personal data about you:
- Professional Contact Data
- Identity Data
- Internet Identifiers or other Electronic Network Activity Information
- Professional or Employee Related Information
- Tradeweb Relationship and other Commercial Information
- Product or Subscription Usage Data
- Publicly Available Information
- Personal Data collected from third parties
- Referrals
- Surveys, competitions, prize draws
3. Sources of Personal Data
We collect the personal data described above from one or more of the below sources:
- Directly from you throughout our relationship, including when you sign up for, and/or use, our products, services, and websites, or when you visit our offices or attend a Tradeweb event;
- Indirectly from you, for example, from observing your actions on our websites or other Tradeweb clients including referrals;
- From our parent entities, affiliates, subsidiaries, and partners;
- From publicly available sources of information.
- From third parties that are authorized to share your information with us, such as intermediaries, broker dealers, our institutional clients and service providers; and
- Your participation in our competitions, prize draws, or surveys.
Please note that if you fail to provide us with personal data which we are obliged to collect by law, or under the terms of a contract that we have in place with you, then we may not be able to provide our products and services to you, but will notify you if this is the case at the time.
4. Purposes for which we collect and use Personal Data
We process personal data for the following purposes:
- Set up your access to a product or service that you have subscribed for and to manage invoicing and payments.
- Provide you with our products and services and to assist you in your use of these including providing any necessary operational assistance, support and training, and alerting you to product changes or maintenance periods.
- Contact you by e-mail, post or telephone with information about Tradeweb, the products and services you use, other Tradeweb products and services similar to those you use and events that might be of interest to you or your organization. You may ask us to refrain from sending you marketing messages at any time as described in the "Contact Details" section of this Privacy Statement.
- Respond to your inquiry, and to contact you about any products or services that you confirm to us that you are interested in hearing about.
- Contact you to ask you to participate in surveys and questionnaires to improve, customise and enhance our products and services. In addition, we can use aggregate anonymized data for statistical purposes, or to plan and implement developments of, and enhancements to, our products and product range.
- Conduct know-your-client (KYC) and other compliance checks on our clients, and conduct system monitoring which Tradeweb is required by law to carry out; and
- Comply with our regulatory record-keeping obligations.
5. Disclosing Personal Data
Tradeweb group companies
We disclose personal data with other companies within the Tradeweb group of companies acting as joint controllers who are based in the United States, Europe, Australia and those countries within Asia where we have a physical presence in order to provide operational and system administration services or for legal and compliance purposes.
Your employer
We will provide your employer with reports containing the product usage data of its employees, for example our gold reports or our dealer resource centre reports.
Content Providers
We will disclose personal data with 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.
Collaboration products
Some of our products, such as messaging or trading products, require you to submit information about yourself in order to participate in the collaboration services provided by that product. At the point at which you submit your personal data, we will tell you more about how that information will be used within the product and, where applicable, your choices in respect of that use.
Vendors
We use other companies as data processors to process certain personal data on our behalf, including service providers who have access to your personal data in order to assist us in our administration of the services or provider other operational or system administration services. For example, we use:
- Customer relationship management software providers in order to assist with the provision of our services and to contact you;
- Subscription management providers who facilitate our distribution of some of our educational/knowledge materials;
- Marketing services including joint webinars where we disclose contact information with the sponsor/presenter;
- KYC and regulatory screening providers who assist us with meeting our compliance obligations;
- Providers who provide system administration support services.
Where appropriate, we may also provide certain personal data to other vendors to process on your behalf, such as clearing houses. These 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.
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 such 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 entities, vendors, or 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.
6. Transfer of Personal Data to Other Countries
As the Tradeweb system is a global operation, we disclose personal data within the Tradeweb group of companies which involves transferring it to different countries, including the United States, Europe, Australia, and those countries in Asia where we have a physical presence.
We ensure that your personal data is protected by requiring our relevant group companies to sign an intragroup personal data transfer agreement which contains legally binding obligations to safeguard your personal data.
7. Storing and Retaining your personal information
Tradeweb will retain your personal data for as long as required for the purposes for which it was collected and in compliance with our obligations under legal, regulatory, tax, accounting, and necessary technical requirements. Tradeweb may retain your personal information for longer periods of time if required to do so according to our regulatory obligations or where we believe necessary to establish, defend, or protect our legal rights or those of others.
8. Security
We maintain appropriate administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data you provide to us. We also limit access to your personal data to those employees, agents and contractors and other parties who have a business need to access your data. They will only process your information in accordance with our instructions and are subject to a duty of confidentiality.
9. Cookies
To learn about how and why we use Cookies, and how to manage them, please see our Cookie Policy.
10. 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 appropriate Tradeweb website, of any significant changes.
Last updated: February 14, 2024
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.
EU and UK Privacy Notice
1. Personal Data We Collect
Personal Data we collect will fall within one of the following categories:
|
Category |
Examples |
|
Professional Contact Data |
|
|
Identity Data |
Your name, government issued identifiers (passport number), other unique identifiers such as date of birth, and personal descriptors that might identify you |
|
Internet Identifiers or other Electronic Network Activity Information |
Details about your devices and technology that you use to access our services, including IP address, your username, and password, and the information we obtain on your technical profile through our use of cookies on your browser (see Section 8 for further details) |
|
Professional or Employee Related |
Details about your work or profession, nationality, education |
|
Tradeweb Relationship and other Commercial Information |
This is data we obtain from our interactions with you, and includes details of any calls you have made to our 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 the Tradeweb events you have attended, and your preferences in receiving marketing communications from us |
|
Product or Subscription Usage Data |
Information about how and when you use our products and services, and the content and functionality you have used in those products and services |
|
Publicly available data |
Details about you that are in public records and information about you that is openly available on the internet |
|
Location |
Data we receive about where you are |
|
Communications and CCTV |
Information we capture through your communications with us, e.g. voice recordings of telephone conversations, emails and instant messaging, and CCTV images if you visit our offices |
|
Personal data collected from third parties |
Data we obtain from Tradeweb 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 |
Data we obtain from other Tradeweb companies or through our Tradeweb website or other Tradeweb clients |
|
Surveys, competitions and prize draws |
Data you provide us with when you participate in our competitions, prize draws or surveys |
2. European Specific Legal Disclosures
Legal Basis for Processing
If you are located in the EU or the UK, the below legal bases apply to Tradeweb’s processing of the personal data that you provide to us where Tradeweb Europe Limited and/or Tradeweb EU B.V. is the data controller. Note that we process personal data on more than one lawful ground depending on the specific purposes for which we are using personal data.
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Purpose for Processing |
Type of Data |
Lawful basis for Processing |
|
Account set up and administration |
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|
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Provision of service |
|
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Sales and Marketing |
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Product development and improvement |
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Compliance checks and regulatory record-keeping |
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3. Transfers of Personal Data outside of the EU or the UK
If you are located in the EU or the UK, the personal data that we collect from you will be transferred to and processed in the United States, Australia and those countries within Asia where we have a physical presence by the Tradeweb group of companies, any may also be held on servers globally by some of our service providers. We ensure that any personal data which is transferred by us outside of the EU or the UK is appropriately safeguarded by using either of the following legal mechanisms:
- The transfers of personal data are based on (i) for transfers from the EU, the European Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision (EU) 2021/914, and (ii) for transfers from the UK, the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner.
- The transfer is to a country that has been designated as providing an adequate level of protection for personal data by the European Commission or the UK government, as applicable.
For further information on our legal safeguard mechanisms used when transferring personal data outside of the EU or the UK, please contact us using the details in section 6 below.
4. Your legal rights if based in the EU or the UK:
You have certain rights afforded to you under European and UK data protection laws in relation to our processing of your personal data if you are based in the EU or the UK:
- 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 or UK 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 or UK 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.
Tradeweb EU B.V. is responsible for the processing of personal data within the EU, and Tradeweb Europe Limited is responsible for the processing of personal data within the UK. Each entity is the “controller” for your personal data when you subscribe to a product or service within the EU or UK, as applicable. 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 using the details in section 6 below.
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 and UK 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) and in the Netherlands is the Dutch Data Protection Authority.
5. Data retention period
In the EU and the UK, 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 anonymised (i.e. so that you are no longer identifiable) for statistical and research purposes for an indefinite period of time without further notice.
6. Contact Details
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 call us on +1 833-917-8850 (USA) +44 (0)20 7776 3200 (Europe) +81 (0)3 6441 1020 (Asia) or email us at privacy@tradeweb.com
Address in the EU:
Tradeweb EU B.V. & Tradeweb Execution Services B.V.
Strawinskylaan 457
1077 XX, Amsterdam
For the attention of: Data Protection Representative
Address in the UK:
Tradeweb Europe Limited & Tradeweb Execution Services Limited
1 Fore Street Avenue
London EC2Y 9DT
For the attention of: Data Protection Representative
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 Tradeweb about the products and services we provide, please select email preferences via the preference center link which is located at the bottom of all of our marketing emails.
Australia Privacy Notice
1. How we hold personal data
We store personal data in servers globally. See section 8 above for information on security measures that we take in relation to personal data.
2. Disclosing personal data outside Australia
The personal data that we collect from you will be transferred and processed between the EU and the UK, and also in the United States and those countries in Asia where we have a physical presence, by the Tradeweb group of companies, and may also be held on servers globally, for example in Canada, by some of our service providers.
3. Your legal rights if based in Australia:
You have certain rights afforded to you under Australian privacy laws in relation to our processing of your personal data if you are based in Australia:
- Access: the right to request access to your personal data.
- Correction: the right to request correction of the personal data that we hold about you or to have incomplete personal data completed.
- Withdraw consent: where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time.
4. Contact details for Australian access requests and complaints
Tradeweb Australia Pty Ltd. is responsible for the processing of personal data of individuals located in Australia. You may at any time submit a request to exercise any of your above rights, or a complaint that we have breached the Australian Privacy Principles, by contacting us by email or post at:
Tradeweb Australia Pty Ltd.
Level 6, 14 Martin Pl
Sydney NSW 2000
For the attention of: Data Protection Representative
Email: privacy@tradeweb.com
Our Data Protection Representative will investigate complaints and determine whether a breach has occurred and what action, if any, to take. We will respond in writing within 30 days of receiving a complaint.
If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC):
Office of the Australian Information Commissioner
Complaints must be made in writing.
1300 363 992
Director of Compliance
Office of the Australian
Information Commissioner
GPO Box 5218
Sydney NSW 2001
www.oaic.gov.au
Privacy Notice for California Residents
1. Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Under the CCPA, personal information further includes “sensitive personal information” such as Social Security number, driver’s license number, passport number, biometric data, and racial and ethnic origin. In particular, we may have collected the following categories of personal information from our consumers within the last twelve (12) months:
|
Category |
Examples |
|
Identifiers |
Name, alias, home and work addresses, home and work phone numbers, mobile phone number, your username, password, Social Security number, driver’s license number, passport number, signature, or other similar identifiers, personal and work email address, IP address, and electronic device (“Device”) identifier |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
Address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history. Some personal information included in this category may overlap with other categories. |
|
Protected classification characteristics under California or federal law |
Age (e.g., 40 years or older as defined in the Age Discrimination in Employment Act of 1967), race, colour, national origin, citizenship, marital status, gender, and veteran or military status. |
|
Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
|
Biometric information |
Fingerprint and Voiceprint |
|
Internet or other similar network activity |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
|
Geolocation data |
Physical location or movements. |
|
Sensory data |
Audio recordings, video recordings, and photographs |
|
Professional or employment-related information |
Current or past job history or performance evaluations. |
|
Inferences drawn from other personal information |
Profile reflecting a person’s preferences relating to financial content or social media industry member groups (e.g., industry knowledge or tools/technology) and characteristics (e.g., age, education, household income). |
|
Sensitive Personal Information categories |
A Social Security number, driver’s license, state identification card, passport number; consumer’s racial or ethnic origin and political affiliation. We limit the use of sensitive personal information to only the purposes necessary to perform the services you receive. |
2. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To manage our relationship with you or your business;
- To process your requests, transactions, and prevent transactional fraud;
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website
- To help maintain the safety, security, and integrity of our websites, software, systems, networks, products, services, databases other technology assets, and business;
- For testing, research, analysis, and product development, including to develop and improve our websites, mobile apps, products, and services;
- To develop new ways to meet our clients’ needs and to grow our business, for example by seeking client feedback or sharing our market research;
- To develop and carry out marketing activities in order to keep our clients informed about our products and services;
- To respond to requests by law enforcement and our regulators and as may otherwise be required by applicable law, court order, or governmental regulations;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tradeweb’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Tradeweb is among the assets transferred; and
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
Tradeweb will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Tradeweb does not use or disclose sensitive personal information to infer characteristics about you and only uses this data for the above business purposes.
3. Disclosure of Personal Information
In the preceding twelve (12) months, Tradeweb may have disclosed the following categories of personal information for a business purpose:
- Personal information categories listed in the California Customer Records statute.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Biometric information.
- Internet or other similar network activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
- Inferences drawn from other personal information.
In the preceding twelve (12) months, we may have disclosed your personal information for a business purpose to the following categories of parties:
- Parent entities, affiliates, and subsidiaries that help provide services to you;
- Business partners that help provide services to you;
- Service providers who help manage, develop, and analyse our business and/or deliver services to us and our clients.
- Agencies and organizations working to prevent fraud in financial services to protect the interests of Tradeweb and to comply with law and regulations;
- Law enforcement, regulatory and other governmental agencies to comply with applicable laws, court orders, or governmental regulations;
- Any potential or actual purchasers of Tradeweb assets where consumer information may be among those assets transferred.
4. Your Rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.
Subject to legal and other permissible considerations, we will use reasonable efforts to honor your request promptly or inform you if we require further information to fulfill your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access your personal information
You have the right, subject to certain exceptions, to request that Tradeweb disclose certain information to you about our collection and use of your personal information.
We will disclose to you:
- The categories of personal information we collected about you,
- The categories of sources for the personal information we collected about you,
- Our business or commercial purpose for collecting that personal information,
- The categories of third parties with whom we sell, share, and/or disclose that personal information,
- The categories of personal information that each recipient received, and
- The specific pieces of personal information we collected about you.
Right to correct or delete your personal information
You have the right to request correction of any inaccurate information relating to you and deletion of any personal information we hold about you, subject to certain exceptions.
For example, we are not required to comply with your request to delete personal information if the processing of your personal information is necessary for compliance with a legal obligation, or for the establishment, exercise, or defence of legal claims.
5. Exercising Your Right to Access, Correct, and Delete
To exercise the access, correction, and deletion rights described above, please contact us using the details in section 9 below.
The verifiable consumer request must:
- Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Once we have verified your request, we will confirm your request and typically will get back to you within 45 days with a response. If we cannot respond within that timeframe, we will let you know we need additional time. 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 Tradeweb about the products and services we provide, please select email preferences via the preference center link which is located at the bottom of all of our marketing emails.
6. Authorized Agent
Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
7. Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services;
- Charge you different prices or rates for services; including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of services; or
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
8. Contact Details
Please do not hesitate to contact us if you have any questions or comments about this notice, the ways in which Tradeweb collects and uses your personal information, your choices and rights regarding such use, wish to exercise your rights under California law, or wish to receive a written copy of this notice.
You may call us on +1 833-917-8850, email us at privacy@tradeweb.com or post at:
Tradeweb Markets LLC
1177 6th Ave. New York, NY 10036
For the attention of: Compliance Team