This policy (the “Privacy Policy”) explains the manner in which 4Xhub Global Ltd (4Xhub Global) collects, utilizes and maintains personal information (“personal information”) about Clients (i) based in the United Kingdom (“UK”), European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK Data Protection Act 2018 (“DPA”) and/or (ii) pursuant to, and in accordance with, the Cayman Islands Data Protection Law, 2017 (the “DPL“), together referred to as the “Data Protection Laws”.
In our use of personal information, we will be characterised as a “data controller” for the purposes of the Data Protection Laws, to the extent applicable. Our affiliates and delegates may act as “data processors” for the purposes of the Data Protection Laws.
Collection of Client personal information
4Xhub Global Ltd collects personal information about Clients, such as Clients’ names, contact details and financial information, from the following sources:
Why we use Clients’ personal information
Your personal data may be processed by 4Xhub Global Ltd :
Disclosure of personal information
4Xhub Global Ltd may share personal information about Clients or potential Clients with affiliates and non-affiliated third parties, as permitted by law (for example, we may share personal information with service providers, and other third party service providers engaged by 4Xhub Global Ltd in order to process the data for the above mentioned purposes). Such service providers are contractually restricted from using Client information in any manner other than as mentioned above.
4Xhub Global Ltd may share personal information, without a Client or potential Client’s consent, with affiliated and non-affiliated parties in the following situations, among others:
1. To respond to any legal and administrative proceedings, regulatory investigations or enforcement actions;
2. In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
3. To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities;
4. To service providers in connection with the administration and operations of the account, which may include brokers, attorneys, accountants, auditors, technology providers, administrators or other professionals;
5. To assist 4Xhub Global Ltd in offering 4Xhub Global Ltd affiliated products and services to its Clients; and
6. To process or complete transactions requested by a Client.
4Xhub Global Ltd may disclose your personal information to competent authorities (including tax authorities), courts and regulatory bodies as required by law or requested or to affiliates for internal investigations and reporting.
International Transfer of Data
The disclosure of personal information to the third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the EEA, UK and/or the Cayman Islands in accordance with the requirements of the Data Protection Laws, as applicable. Such countries may not have the same data protection laws as your jurisdiction. As your data controller, we will ensure that where your personal data is processed in such countries, there is an adequate level of protection and/or we use an appropriate transfer mechanism to ensure your information is subject to adequate safeguards in the recipient country. You may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
Collecting personal information Legally
4Xhub Global Ltd is able to legally collect and use your personal information because collecting and using your personal information is necessary for us to: (a) enable the account to function; and/or (b) carry out its legitimate interests in carrying out any requests or orders made by a Client and complying with applicable law. Where 4Xhub Global Ltd requires your personal information to comply with AML or other legal requirements, failure to provide this information may mean that you will be unable to be accepted as a Client or continue as a Client.
Retention of personal information
4Xhub Global Ltd will retain your personal information for as long as required for us to perform the Services or perform investigations in relation to the Services and in order to enable us to comply with our legal obligations and exercise our legal rights.
Your Rights
You have the right in certain circumstances to:
1. be informed about the personal information 4Xhub Global Ltd collects from you and uses, which this Privacy Policy seeks to do;
2. obtain confirmation from 4Xhub Global Ltd that your personal information is being collected and used by 4Xhub Global Ltd and to access the personal information held by 4Xhub Global Ltd;
3. have your personal information corrected if it is inaccurate or incomplete at any time;
4. erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information 4Xhub Global Ltd holds about you at any time, subject to 4Xhub Global Ltd’s legal obligations;
5. block or suppress 4Xhub Global Ltd collecting and using your personal information, which means we can continue to store such personal information but cannot further collect or use it in any way;
6. obtain and reuse any personal information 4Xhub Global Ltd holds about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from 4Xhub Global Ltd to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
7. object to 4Xhub Global Ltd collecting or using your personal information where this is based on:
1. a legitimate interest or the performance of a task in the public interest; or
2. direct marketing.
To make any requests as listed above, please contact the 4Xhub Global Ltd at info@4xhubglobal.com.
4Xhub Global Ltd will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where the request is more complex.
Withdrawal of Your Consent
Where 4Xhub Global Ltd has obtained your consent to process your personal information, you can withdraw your consent by emailing 4Xhub Global Ltd at info@4xhubglobal.com.
Former Clients
This Privacy Policy applies to former Clients in the UK, EU, and EEA for the purposes of the GDPR and DPA, for all former Clients in respect of DPL, and for all former clients in respect of CFTC and NFA Privacy Rules, to the extent applicable.
Protection of personal information
4Xhub Global Ltd maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the Data Protection Laws to protect personal information, including:
Further Information
This Privacy Policy replaces all previous disclosures we may have provided you about our information practices in the UK, EEA, EU, the Cayman Islands and other jurisdictions. 4Xhub Global Ltd reserves the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. This Privacy Policy complies with the Data Protection Laws regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this Privacy Policy, please e-mail info@4xhubglobal.com.
Making a Complaint
If you would like to make a complaint about the way 4Xhub Global Ltd has collected or used your personal information, please contact us at info@4xhubglobal.com.
You have the right to lodge a complaint with (i) the Information Commissioner’s Office (“ICO”) if you consider that the processing of personal data relating to you carried out by 4Xhub Global Ltd or its service providers infringes the DPA, (ii) a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by 4Xhub Global Ltd or its service providers infringes the GDPR or (iii) the Ombudsman’s office of the Cayman Islands if you consider that the processing of personal data relating to you carried out by 4Xhub Global Ltd or its service providers infringes the DPL.