DT Transaction Reporting

This Notice explains how we at DataTracks collect, use, retain and disclose Personal Data collected from you while using our product.

Our Commitment

Our information handling practices are continually reviewed to ensure that they comply with the European Union General Data Protection Regulation (GDPR), 2018 as well as “Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011” under Section 43A of the Indian Information Technology (Amendment) Act, 2008.

Information Collection

We collect your Personal Data in the following ways:

Through information provided by you when you contact us as subscribed user of our MiFID II product
1. You provide us your username, official email address and profile picture
2. You chat with us using Bitrix chat, where we collect your name, email address and phone number
3. You provide us files for processing that contain information that includes first name, surname, date of birth, identifier code (Could be passport number or national ID or LEI or CONCAT) and country with respect to your organization’s buyers, sellers, buyer decision makers and seller decision makers.

Through log files on our product website
As a user when you access our product, we track changes made to the reportable data within the product along with a time stamp through your user name.

Through cookies on our product
The cookies collect information about you when you use our product. For more information about cookies, please refer to the ‘Cookies Information’ section on this Notice

Information Purpose & Usage

We use the collected Personal Data for:

Preparing a valid report for submission to regulator
Providing Support/Assistance for processing
Creating users in the product
Tracking your activities on our product

We retain and use your Personal Data as long as it is necessary for fulfilment of the respective purposes as specified in this section.

Choice & Consent

On our product, every page that collects Personal Data from you, states the purpose of collection of information. If you agree to the purpose, you can provide your information and thus give your consent to us to use the information provided for the stated purpose.

If, at any point, we decide to use your Personal Data for a different purpose, we will notify you and obtain your consent.

You can withdraw your consent at any point in time by reaching out to us at the details mentioned in the ‘Contact Us’ section. Consequences of withdrawal will be communicated to you on contacting us and on your agreement, your request for withdrawal will be processed.

Cookie Information

Cookies are small text files that are placed on your computer by product websites that you visit. They are widely used in order to make product websites work, or work more efficiently, as well as to provide information to the owners of the product website.

Below is a list of cookies used on our MiFID II product along with a description of what they are used for.

Sl. No.	Name of Cookie	Owner	1^st/3^rd Party	Expiry period	Purpose
1	ASP.NET_SessionId	DataTracks	1st Party	valid till browser session	To track the current session
2	BX_USER_ID	BitriX24	3rd party	10 Years	To track the unique visitors approaching for the chat support.
`3`	b24_sitebutton_hello	BitriX24	3rd party	valid till browser session	To track the chat history.

You can find more detailed information about cookies and adjusting your browser settings to refuse the use of cookies by visiting http://www.allaboutcookies.org/manage-cookies/.

For more information on Bitrix24 cookies visit:

https://www.bitrix24.com/privacy/

Bitrix24 is governed by its own privacy policy. Please go through its privacy policy to get information on its Privacy Practices.

Disclosure

We use services of Rackspace Cloud Computing to store your Personal Data that you provide us on our product website. Rackspace provides services to us under extremely strict confidentiality agreements and do not have any independent right to share this information with any entity without our permission.

We use services of third party database provider called OpenLEIs to validate LEI codes in the report before submission to the regulator.

Personal Data collected from you will not be disclosed without your consent. Exception to this is when such disclosure is necessary for compliance to any legal and/or law enforcement obligations. We will do so after following necessary due processes.

We will make every effort, where possible, that such mandated disclosures are communicated to you.

Access & Correction

You can update or correct your Personal Data collected from you, by calling our support contact number available on our product website.

Data Security

We are committed to protecting your Personal Data in our custody.

We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Data from unauthorized access, alteration, transmission and deletion.

Data Transfer

We process the financial files provided by you on your request, outside the European Economic Area. These contain counterparties’ Personal Data. You can contact us to obtain a copy of safeguards provided to the Personal Data which is transferred. Contact details are provided in the “Contact Us” section.

Children’s Privacy

Our product website is not designed to be used by children aged below 16. Personal Data of children will not be knowingly collected by us.

Notification of Changes

We reserve the right to amend this Privacy Notice at any time. We will update our Privacy Notice with a new effective date stated at the beginning of it. Our processing of your Personal Data will be governed by the practices set out in that new version of the Privacy Notice from its effective date onwards.

Rights provided to you under GDPR

In case you are accessing the product website from within the European Economic Area, we are committed to providing you with the following additional rights which you can exercise:

Rights under GDPR	How we facilitate your rights
Right to be informed	We aid this right to you through our Privacy Notice OOur Privacy Notice communicates how we handle your Personal Data collected through our product website. For any further information, feel free to contact us
Right of access	You can contact us to get access to your Personal Data along with information regarding its purpose, disclosure, categories of Personal Data, storage period, source of collection of Personal Data, confirmation whether or not they are being processed
Right to rectification	You can call our support contact number available on our website to get the information corrected
Right to erasure	You can contact us to get your Personal Data deleted or erased
Right to restriction of processing	You can contact us and request restriction of further processing
Right to data portability	You can contact us to get your Personal Data in a structured, machine-readable format and if you want, can have it transmitted to another organisation
Right to object	We do not use your Personal Data for direct marketing purposes
Right not to be subject to Automated individual decision-making, including profiling	We do not process your Personal Data for automated decision making including profiling
Right to lodge a complaint with the Supervisory Authority	You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available at: https://ico.org.uk/global/contact-us/

We will verify your identity when you exercise these rights. For exercising your rights and getting information about any limitations which apply on them, you can reach out to us at the contact details given below.

Contact Us

For any further queries and complaints related to privacy, or exercising your rights under GDPR, you could reach us at:

Name of Person: Sriraman Ranganathan

Contact Number: +44 (20) 3608 1300

Contact Email ID: cfo@datatracks.com

DTracks Limited
Belgrave House, 39-43 Monument Hill,
Weybridge, Surrey, KT13 8RN
United Kingdom

Your queries will be addressed within one month of receipt of such requests. In case of any delay in addressing such requests, the delay will be communicated to you within the same month of receipt of request.

Consent for Chat system

We use Bitrix24 system for chatting through the application

		Click on check box to accept
1.	We collect your name, email address and phone number through the chat window for identification of the person initiating the chat. We collect the screenshots of any application screens having the reportable data or collect the file in any format through the chat window for the purpose of trouble-shooting.
2.	The processing of information collected through Bitrix chat is done outside EEA.