1. Data Controller

EM Credit Financial & Management Ltd. (“EM Credit”, “we”, “us”, “our”) is the data controller responsible for your personal data. We are registered in England and Wales (Company No. 11234567) with our registered office at A11 2 Alexandra Gate, Cardiff, CF24 2SA, United Kingdom.

For data protection inquiries, please contact us at trading@emcredit.uk.

2. Information We Collect

We may collect and process the following categories of personal data:

2.1 Information You Provide Directly

Identity Data: Full name, job title, company name
Contact Data: Email address, telephone number, business address
Inquiry Data: Product interest, message content, and any details you provide through our contact form or correspondence
Document Access Data: Name, email, and company information submitted when requesting access to protected documents

2.2 Information Collected Automatically

Technical Data: IP address, browser type and version, operating system, time zone setting
Usage Data: Pages visited, time spent on pages, navigation paths, referring URLs
Security Data: reCAPTCHA tokens and scores for bot protection (processed by Google)

3. How We Use Your Data

We process your personal data for the following purposes and on the following lawful bases under UK GDPR Article 6:

To respond to your inquiries (Lawful basis: Legitimate interests / pre-contractual steps) — processing your contact form submissions and matching you with the appropriate trading desk
To send confirmation emails (Lawful basis: Legitimate interests) — acknowledging receipt of your inquiry
To provide document access (Lawful basis: Legitimate interests) — managing PIN-based access to company documents
To protect against fraud and abuse (Lawful basis: Legitimate interests) — rate limiting, reCAPTCHA verification, and security monitoring
To comply with legal obligations (Lawful basis: Legal obligation) — retaining records as required by applicable laws and regulations, including FCA requirements

4. Data Sharing

We do not sell your personal data. We may share your data with:

Service Providers: Email hosting and SMTP services for delivering communications
Google reCAPTCHA: For bot protection and security verification (subject to Google’s Privacy Policy)
Legal and Regulatory Authorities: Where required by law, court order, or regulatory obligation (including the FCA, HMRC, or law enforcement agencies)
Professional Advisors: Lawyers, auditors, and insurers where necessary for the provision of their professional services

5. International Data Transfers

Where your data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements. This may include reliance on adequacy regulations, standard contractual clauses, or the International Data Transfer Agreement (IDTA) as applicable.

Google reCAPTCHA may process data in facilities outside the UK. Google operates under appropriate safeguards for international transfers. For more information, please refer to Google’s data processing terms.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

Contact inquiries: Retained for up to 3 years from the date of last interaction, or longer if required for ongoing business relationships
Document access PINs: PINs expire after 24 hours. Associated request data may be retained for audit purposes
Technical and security logs: Retained for up to 12 months
Regulatory records: Retained in accordance with FCA record-keeping obligations (minimum 5 years)

7. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

Right of Access: Request a copy of the personal data we hold about you
Right to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure: Request deletion of your data where there is no compelling reason for continued processing
Right to Restrict Processing: Request a limitation on how we use your data
Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format
Right to Object: Object to processing based on legitimate interests

To exercise any of these rights, please contact us at trading@emcredit.uk. We will respond within one month of receipt. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.

8. Cookies

This website uses strictly necessary cookies for site functionality and security. We use Google reCAPTCHA v3 which may set cookies to assess the risk of automated abuse. No marketing or analytics cookies are used without your consent.

For more information about how Google reCAPTCHA uses cookies, please refer to Google’s Privacy Policy.

9. Security

We implement appropriate technical and organisational measures to protect your personal data, including encrypted communications (TLS/SSL), rate limiting, brute-force protection, and regular security reviews. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legislation. Any material changes will be communicated by updating the “Last updated” date at the top of this page. We encourage you to review this policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Email: trading@emcredit.uk
Address: EM Credit Financial & Management Ltd., A11 2 Alexandra Gate, Cardiff, CF24 2SA, United Kingdom