Privacy Notice
Artemeter LLC and its affiliated companies (collectively, “Artemeter”, “we”, “us”, or “our”), are committed to transparency in the collection and use of your personal information.
This notice (the “Privacy Notice”) sets forth a description of how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Notice also describes your data protection rights and how you may exercise them, as set out below.
This Privacy Notice applies to all visitors to Artemeter’s website, located at drw.com/artemeter (the “Website”).
Collection and use of information
Artemeter may collect and use personal information, such as your name, address, email address, signature, and other information, in connection with the following:
- Visiting our Website;
- Applying to onboard with us;
- Communicating with us (e.g., contacting us with a comment, question, or complaint);
- Safety and security; and
- Complying with applicable laws and regulations.
Onboarding Information: To onboard as a counterparty through our Website or through other means, we may require you to provide us with certain personal information, including, but not limited to, your full name, email address, residential address, birth date, phone number, country of residence and nationality, employment information and status, national and governmental identification information, and financial and banking details, including any joint account holders and people appointed to act on your behalf. Artemeter uses this information to undertake anti-money laundering and fraud prevention activities and know your customer reviews.
If you do not provide required personal information, it may mean that we are unable to onboard you or provide you with services and perform all of our obligations under our agreement(s) with you.
If you provide us the personal information of other persons (such as joint account holders), you confirm that they are aware of the information in this Privacy Notice concerning how we will use their personal information, including, but not limited to, use of their personal information to provide services and our disclosure of personal information to third parties (e.g., to provide payment initiation).
Once you have been onboarded as a counterparty, Artemeter will continue to use this information as necessary to effect transactions with you.
We may also obtain information about you from other sources, including identity verification services, fraud prevention agencies, websites and other publicly accessible information. We will also receive data you submit to us through third-party websites.
Communications: You may request to receive communications about Artemeter through our Website or connect with us on third party websites (including through social media sites). If you sign up through our Website or request to receive communications from us, we collect certain personal information (such as first and last name and email address) which we use to send you email and other communications to keep you informed about our events and to tell you about services that may be of interest to you.
Contact Information: When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, phone number, and email address) along with additional information we need to help us answer your question or respond to your comment or complaint.
Recording Information: If required for legal and regulatory purposes, your communications with us may be recorded.
Social Media Information: If you interact with us through social media or other channels, we may store the details of these interactions.
Automatically-Collected Information: We may collect the IP (Internet Protocol) addresses of visitors to our Website and other related information, such as page requests, browser type, operating system, average time spent on our Website, and how you are using our Website. We use this information to help us understand activity on our Website and to monitor and improve our Website. We may also collect information from your digital devices to perform checks required to meet our regulatory obligations; for example, we may identify your IP address in order to ascertain and verify your residency status.
Information Collected with Consent: Where your consent is required by law, we may seek to obtain your consent to collect and use certain types of personal information. If we ask for your consent to process this personal information, you may have the right to withdraw your consent.
Purposes & lawful basis
Purpose: Onboarding and trading activities
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is permitted with your consent
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include administration of onboarding and trading activities, use in connection with legal and compliance, auditing, and regulatory reporting requirements
Purpose: Communications relating to legal, regulatory, and account servicing
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include sending notices and exchanging required information, use in connection with legal and compliance, auditing, and regulatory reporting requirements
Purpose: Managing complaints, undertaking remediation activities, and resolving queries
Lawful basis for data processing:
- Purpose: Managing complaints, undertaking remediation activities, and resolving queries Lawful basis for data processing:
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include resolving and investigating complaints and improving our services
Purpose: Monitoring communications to check your instructions to us, analyze and improve our services, and for training and quality purposes
Lawful basis for data processing:
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include developing and improving our systems, training our staff, and providing a high standard of service
Purpose: Undertaking checks for security, fraud prevention, anti-money laundering and verifying identity (both before providing services and when communicating to ensure we are dealing with the correct person)
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include use in connection with legal and compliance, auditing, and regulatory reporting requirements
Purpose: Recovering debt and enforcing other obligations as our agreement entitles us, as well as to protect our rights and property interests
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include recovering debts owed to us and protecting our assets
Purpose: Providing payment initiation services for accounts you hold with other providers
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is permitted with your consent
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
Purpose: Complying with regulatory and legal obligations and cooperating with regulators and law enforcement
Lawful basis for data processing:
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include use in connection with legal and compliance, auditing, and regulatory reporting requirements
Purpose: Preparing high-level anonymized statistical reports, which may be shared with third parties or used for our own analytical purposes
Lawful basis for data processing:
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include analyzing our services and how they are used to identify potential improvements
Purpose: Website related activities (e.g., dealing with inquiries, running analytics)
Lawful basis for data processing:
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is permitted with your consent
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include operating the Website and its related functionalities, improving the Website, analyzing Website visitor and usage data, and protecting our systems and networks
Purpose: Marketing communications
Lawful basis for data processing:
- Processing is necessary for the legitimate interests pursued by Artemeter or others, which include providing you with information about products and services that may be of interest
- Processing is permitted with your consent
Purpose: Processing personal information to comply with regulatory and legal obligations and cooperate with regulators and law enforcement
Lawful basis for data processing:
- Processing is necessary for compliance with a legal obligation to which Artemeter is subject
- Processing is in the public interest
Disclosure and transfer of information
We do not sell, rent, or trade your personal information. However, we may disclose, transfer, or otherwise make your personal information available as follows:
Service Providers: Your personal information may be disclosed, transferred, or otherwise made available to our affiliates and other third parties who provide services such as identification and background checks, cloud-based information hosting and maintenance, website hosting, record keeping, and analytics, and to exchanges, trading platforms and financial institutions.
Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law, or for detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims, and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Your personal information may be provided to third parties in connection with a
business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Artemeter or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
International Transfer: Your personal information may be stored and processed by us, our affiliates, and other third-party service providers in the United States and other countries outside of the United Kingdom and the European Economic Area. With respect to transfers out of the United Kingdom and the European Economic Area, we have taken steps to provide an adequate level of protection for your personal information in accordance with applicable law, including, for example, through the use of an approved transfer mechanism (e.g., Standard Contractual Clauses). You may obtain further information by contacting us using the details set out later in this Privacy Notice.
Safeguarding and retention of personal information
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. We have employed reasonable measures designed to restrict access to your personal information to employees and authorized service providers who require access to fulfill their job requirements.
We retain personal information for a length of time commensurate with the purposes of the processing, which may include legal and compliance purposes, in compliance with applicable privacy laws. Personal information may also be stored, but no longer actively processed, for additional periods of time in the form of data backups and archives.
Rights relating to personal information
Under applicable privacy laws, you may have the right to access, update, correct, and delete your personal information in our custody and control, object to and/or restrict processing of your personal information, and obtain a copy of your personal information in a portable format, subject to certain exceptions prescribed by law. You may exercise these rights by emailing or writing to us at the contact information set out below. Prior to authorizing a request, we may request certain information from you for the purposes of verifying your identity.
These rights may be limited, for example, if the request is manifestly unfounded or excessive, if fulfilling the request would adversely affect the rights or freedoms of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
Where we rely on your consent, you may have the right to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.
If you have unresolved concerns, you have the right to complain to the relevant data protection authority of your applicable jurisdiction.
COOKIES POLICY
Cookies: Our Website may use a technology called “cookies” or similar types of technologies to improve your experience and provide analytics on website interactions. A cookie is a tiny element of data that our Website can send to your browser, which is then stored on your device so that our systems can recognize you when using our Website.
Our Website may use the following types of cookies:
- Essential Cookies: Essential cookies are always active and necessary for our Website to function.
- Functional Cookies: Functional cookies allow us to personalize our Website in accordance with your preferences and interests and support enhanced functionality.
- Analytics Cookies: Analytics cookies help us understand our website activity and to improve our Website, including through the use of Google Analytics. For more information about how Google Analytics may use your personal information, please see www.google.com/ policies/ privacy/ partners/.
Depending on your location, you may be able to manage your preferences in relation to Functional and Analytics cookies using our cookie preferences center, which is accessible here: Cookie Preferences. Please note that if you decide not to accept certain cookies from our Website, you may not be able to take advantage of all of the features of our Website.
Do Not Track Signals: Our Website does not recognize “do not track” signals or similar mechanisms of most web browsers.
Third party websites
Our Website may contain content and links to third party websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect personal information from you, and that collection is subject to the third party’s privacy policy/notice, so please refer to those third-party privacy policies/notices to understand how those parties may collect and/or process your personal information.
SOCIAL MEDIA
We may offer you the opportunity to engage with our content on or through third-party social media websites, plug-ins, and applications, such as Instagram, Twitter, and YouTube. When you engage with our content on or through third-party social media websites, plug-ins, or applications, certain information associated with your social media profile (e.g., name, username, email address, profile picture, and birthdate) may be made available to us.
USE BY MINORS PROHIBITED
The Website is not designed or intended for use by persons under the age of 18, and we do not knowingly collect personal information from minors. If you are under the age of 18, do not use our Website.
UPDATES TO THE PRIVACY NOTICE
We may update this Privacy Notice from time to time to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices, and any use of our Website after any updates constitute your acknowledgement that you have read the updated Privacy Notice.
CONTACT US
Please contact us if:
- you have any questions or comments about this Privacy Notice;
- you wish to access, update, and/or correct inaccuracies in your personal information; or
- you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.
You may contact us by email at media@artemeter.com or by mail at the following addresses:
540 West Madison Street
Suite 2500
Chicago, IL 60661
