OpenGamma Privacy Policy

From time to time, we will review and may make updates to this Privacy Policy. We encourage you to check this page for any changes to the OpenGamma Privacy Policy; your continued use of this site or our Products and Services after any change to this policy will constitute your acceptance of such changes.

 

Our commitment

The OpenGamma group of companies respects the privacy of our visitors and customers, and recognises the need to protect personal information that you provide to us. We have therefore established this Privacy Policy to assist you to understand what personal information we collect and process about you, the purposes of the processing and the rights that you have in connection with it.

This Privacy Policy explains how we collect, share and use collected data, and how you can exercise your privacy rights. For the purpose of this Privacy Policy, “Personal Information” means any information that is available to OpenGamma and that is protected explicitly by the European Union General Data Protection Regulation of 2016 (the “EU GDPR”); The EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 the (“UK GDPR”); United Kingdom’s Data Protection Act 2018 (“DPA”) and the California Consumer Protection Act (“CCPA”), to the extent applicable.

If you are in any doubt regarding the applicable standards or have any comments or questions about this Privacy Policy, please contact us via email privacy@opengamma.com.

This policy was last updated in February 2023.

 

Personal Information We Collect

Personal information is information that can be used to identify or contact a specific individual, such as a name, address, company affiliation, or email address. We divide the personal information we collect into two categories: information you explicitly provide, and information that you casually provide. We use Personal Information mainly to offer our services and enhance our users experience.

Information we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services. We may collect Personal Information such as name, email addresses, phone number, names of contact persons for billing purposes or when you request a demo of our product or services, request sales information, access our product or service or contact customer support. We may also possess your professional or employment related data such as job title and historic employment records when you apply for a job opening, for networking purposes or in order to contact you during the course of our business relationship.

We may keep records of profile data that covers username and password, your preferences and any feedback including when we administrate your company account. We may have products where our Clients have possibility to opt for two-factor authentication for account access, therefore we may ask you to enter a telephone number or email address to set up the process. You may have the option to use that telephone number or email address as the method for us to communicate verification codes to you to verify that it is you logging into your account. We do not use the two-factor authentication phone number or email address for purposes other than providing verification codes; however, if you have provided us with your phone number in another context, we may contact you for that purpose.

On OpenGamma’s websites we may ask for specific Personal Information from you, which will be used to contact you and customise the offerings that OpenGamma makes to you. We will only collect the Personal Information that you knowingly provide to us, and we will only do so when it helps us to tailor our offerings to your interests and request.

In addition, as you browse our website, we may automatically collect information about your time on our site and the content that you access whilst browsing it. While we do not intend any of this information to be Personal Information, it may be possible to combine this information with other information, making it Personal Information. If we do so, passively collected information about your browsing of our websites will be considered Personal Information.

We may use the Personal Information that we collect to exercise what is called our legitimate interests, meaning that we may use the data for reasons that are in your and/or our interest, while ensuring your privacy rights are fully protected. You can opt out of any marketing or communications we make on this basis at any time.

Automatically collected information is analysed to improve our websites and includes without limitation details such as the IP address assigned to you when you accessed our websites, what pages you visited, login data, browser type and version, timezone and location, how long you spent on each page, and how you found the OpenGamma website. This information can be used to answer such questions as “How do people find out about OpenGamma products and services?” and “What are the most popular pages on the OpenGamma web site?”.

We may occasionally combine your Personal Information with information retrieved from other sources, such as public sources which include government agencies, public records, social media platforms and other publicly available sources. We engage with data providers, such as information services and data licensors that provide other information, such as your business contact information.

 

Cookies

The OpenGamma website does use “cookies” on its websites. Cookies are identifiers that can be sent from a web site and placed on your hard drive by your browser, and sent back to OpenGamma when you browse our web site. You may elect not to accept cookies by instructing your browser not to accept cookies from OpenGamma websites, and if you do so, you will still be able to browse our websites. However, certain interactive functionality of our websites may not be available if you do not accept cookies from OpenGamma.

Cookie information is used in much the same way as automatically collected information about your browsing of our websites and may be used to link together multiple visits you may make to our web sites. This information helps us answer questions such as “What product information is most of interest to regular visitors to our web site?” and “What types of offers do regular visitors to our web sites prefer?”.

Our site uses three types of cookies:

  • ‘Analytical’ cookies allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.
  • ‘Functional’ cookies allow us to remember choices you make, such as your log in details. We use these cookies to show you are logged in (where applicable) and display relevant confirmation pages when you interact with our site.
  • ‘Third party’ cookies are set by external web sites whose services are used on this site. They allow you to share content onto social networks and comment on content on the site.

 

Third Party Cookies and Links to Third-Party Web Sites

Third Party Cookies are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site that allow visitors to share content onto social networks and comment on content on the site. In order to connect our site to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing on the internet, including on this web site.

You should check the respective policies of the third-party services to see how exactly they use your information and to find out how to opt out, or delete, such information.

OpenGamma web sites may link to web sites hosted by other firms for your convenience and information. If you visit those web sites, the privacy policy of the firms hosting those web sites will apply instead of OpenGamma Privacy Policy, and we are not responsible for, cookies or pixel tags in third-party ads, and we recommend reading the privacy policies of Third-Party sites and ad services, to understand about their use of cookies and other technologies.

We do not endorse or make any representations about Third-Party web sites, nor can we control how Personal Information you provide to those web sites will be used.

 

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, other details about your visit, and technical details that occur in conjunction with any errors you may encounter.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

 

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

 Our legitimate interests are:

  • delivering, developing and improving our Services and Products;
  • enabling us to improve, modify and customise our Services, Products and communications;
  • expanding our business and carrying out our marketing activities; and
  • improving our Services, customer satisfaction, and data security.

 

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website or directly contacting us:

  • sign up to receive updates from us via email or social media channels;
  • use a mobile device or web browser to access our content;
  • contact us via email, social media (e.g. LinkedIn), or on any similar technologies;
  • when you mention us on social media;
  • when your company or the company you work for uses our services, is a customer or a supplier of ours or when we want to target or advertise our Services;
  • when you form a business relationship with us and during the course of the relationship; and
  • when you are an end user of the Products or Services of ours.

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to enable you to have full access to OpenGamma Products and Services;
  • to respond to your comments, questions, and requests, and provide customer support;
  • to notify you about any changes and improvements to our Products and Services 
  • to monitor and analyse trends, usage, and activities in connection with the OpenGamma Products;
  • to enable you to customise or personalise your experience of our website;
  • for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms;
  • to consider your employment application;
  • to enable you to access and use our website, associated applications, and associated social media platforms;
  • for internal record keeping and administrative purposes; and
  • to comply with our legal obligations and resolve any disputes that we may have.

Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.

 

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

To protect the privacy of this information, OpenGamma and its partners employ industry-standard controls including physical access controls and internet firewalls. We are located in the United Kingdom and the United States of America, however, we may store any information collected in a number of jurisdictions, including but not limited to various states of the United States of America and the European Union. When we transfer personal information outside the EEA we ensure the recipients of this information are subject to the same safeguards and contractual obligations as those required within the EEA.

We are committed to safeguarding your data by implementing the latest technologies and software, which help us safeguard all the information we collect online. We will comply with laws applicable to us in respect of any data breach.

 

How Long We Keep Your Personal Information

OpenGamma retains personal information for as long as necessary to meet our contractual and legal obligations. This time period may depend on what we are using your information for, in accordance with this Privacy Policy. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.

To ensure we do not hold on to personal information for longer than is legally required or necessary, we will delete all your personal information 6 years after the termination of our business relationship.

However, if necessary, we may retain your personal information to ensure we remain in compliance with applicable laws and regulations, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes.

 

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. If we learn that a child under the age of 13 has provided us with Personal Information online without parental consent, we will take reasonable steps to erase such Personal Information from our databases and we will not use any information provided to us, unless where required to protect the child’s interests or as required by the law. If you are a parent or a guardian of a child under the age of 13 and have learned that your child has provided us with Personal Information without your consent, you may contact us at privacy@opengamma.com. 

 

Special Categories of Personal Data

For the purposes of this policy, we do not collect any Special Categories of Personal Data. Special Categories include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

 

Disclosure of Personal Information to Third Parties

OpenGamma will only use your Personal Information within the OpenGamma group of companies, and will not divulge your Personal Information except as set forth in this Privacy Policy. You understand and agree that in order to help you engage with OpenGamma, we may share your Personal Information with employees or contractors of OpenGamma subsidiaries throughout the world, who will all be bound by this Privacy Policy. Specifically, automatically collected information may be collected, stored, and processed by third-party firms (such as through the Google Analytics program).

If you are entering into a business relationship with OpenGamma, and that business relationship involves another vendor of technology or services, you understand that it may be necessary for OpenGamma to share certain details with that third party in order to improve the service offerings we make to you, and you hereby give us permission to do so. Any sharing that we do will be, to the best of our abilities, to your benefit, and partners will be bound by this Privacy Policy.

OpenGamma will not lease, sell, or distribute your personal information to any third parties, unless we have your permission.

We may disclose personal information to:

  • a parent, subsidiary, or affiliate of our company;
  • our third-party partners who may contact you regarding their products or services;
  • third party service providers for the purpose of enabling them to provide their services, for example, IT service providers, data storage, hosting and server providers, advertisers, or analytics platforms;
  • our employees, contractors, and/or related entities;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any competition, sweepstakes, or promotion we run;
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights;
  • third parties, including but not limited to courts, regulatory authorities, solicitors, service providers or business partners to prevent, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattack and identity theft or for any other risk management purposes;
  • professional advisors, such as solicitors, auditors, bankers and insurers, where necessary in the course of the professional service that they provide us;
  • third parties, including agents or sub-contractors, who assist us in providing IT and system administration, credit card processing, data enrichment, information, products, services, or direct marketing to you  and who help us to collect and process data;
  • an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use your Personal Information only for the purposes disclosed in this Privacy Policy; and
  • to any other person with your consent to the disclosure.

Additionally, we may disclose your Personal Information if we have a good faith belief that disclosure is necessary to protect the health, safety, or rights of a third party.

 

International Transfers of Personal Information

The personal information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities. Please be aware that the locations to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

When transferring data outside of United Kingdom to the US, we ensure that we have a relevant International Data Transfer Agreement in place and we conduct Data Transfer Impact Assessment. For our counterparts in the Asia-Pacific region, we respect the principles deriving from the APEC Cross-Border Privacy Rules.

For our European counterparts, we note that the EU-US Privacy Shield is no longer a valid mechanism to transfer personal data from the European Union to the United States and we are committed to follow any updates concerning Trans- Atlantic Data Privacy Framework. We inform that in case of transferring any data concerning EU data subjects, we are following new EU Standard Contractual Clauses (SCCs) approved by the European Commission in Commission Decision 2021/914 on 4 June 2021  and where we act as a processor for our Clients, we follow EEA controller to processor SSCs. 

For our UK data subjects, we ensure we comply with any requirements arising from international data transfer agreement (“IDTA”) and the international data transfer addendum (“Addendum”) issued by the Information Commissioner’s Office and Data Protection Authority. Where we as processors transfer data of UK data subjects, we follow EEA controller to processors SCCs, incorporating the amendments set out in clause 3 (a) and the UK IDTA Addendum.  

 

Your Rights and Controlling Your Personal Information

You always retain the right to withhold personal information from us, with the understanding that your experience of our website may be affected. We will not discriminate against you for exercising any of your rights over your personal information. If you do provide us with personal information you understand that we will collect, hold, use and disclose it in accordance with this privacy policy. You retain the right to request details of any personal information we hold about you and may at any time exercise the right to be forgotten or request partial deletion of the Personal Information we possess.

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email-database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

 

Restricting the Collection of your Personal Data

At some point, you might wish to restrict the use and collection of your personal data. You can achieve this by doing the following:

  • when you are filling the forms on the website, make sure to check if there is a box which you can leave unchecked, if you don’t want to disclose your personal information; or
  • if you have already agreed to share your information with us, feel free to contact us via email and we will be more than happy to change this for you.

 

California Residents Rights

California Civil Code Section 1798.83, allows California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes including the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. All our users who are California residents and would like to receive this information, may send us a request via privacy@opengamma.com. 

Our products and Services are not targeted to minors under the age of 18. However, if you are under 18 years of age, reside in California, and have a registered account with our Services, please contact us in case you have publicly posted any Personal Data that we control. To request the removal, please contact us via privacy@opengamma.com. When you contact us, please provide us with the data you have shared publicly that we control and include a note that you are a resident in the State of California. We will take all reasonable steps that such data will not be publicly displayed.

 

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

 

Changes to This Policy

At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

 

Contact Us

If you have any questions or wish to exercise your rights in relation to this policy then please email privacy@opengamma.com.

If you have any concerns regarding this Privacy Policy, or you believe that the privacy of Personal Information you have provided to OpenGamma has not been respected or maintained according to this policy, you may submit a complaint in writing to the attention of OpenGamma Limited, 5th Floor, One New Change, London, EC4M 9AF, United Kingdom.

Copyright

All content on this web site is copyright 2009-present by the OpenGamma group of companies. All rights reserved.

Trademarks

OpenGamma is a registered trademark of OpenGamma Ltd in the United States of America and the European Union.

All use of the mark(s) referenced above shall be subject to the OpenGamma group of companies’ prior written consent or standard mark usage policies, which may be revoked or modified at any time. Notwithstanding anything to the contrary, all goodwill created in the use of the marks referenced above shall vest solely with the OpenGamma group of companies.

All other trademarks referenced on www.opengammacms.wpengine.com are those of their respective owners.

Company Details

OpenGamma Limited is a company registered in England and Wales with company number 06989069. Registered office: OpenGamma Limited, 5th Floor, One New Change, London, EC4M 9AF.