Privacy Policy — Ulltimate Rewards

Ulltimate Rewards (UR) is committed to protecting the privacy of all personal information that we obtain from you. This Privacy Policy (Privacy Notice) explains how the UR Markets collects, maintains, uses and discloses your personal information. It also provides some detail about the rights that customers have in respect of their personal information. This Privacy Policy applies to all organisations within the UR Markets Group of companies.

Personal information

You provide Ulltimate Rewards with your personal information (including sensitive personal information) when you ask for information about Ulltimate Rewards products and services, when you access and use this and other Ulltimate Rewards websites and/or when you submit an application to open an account with Ulltimate Rewards. When assessing an application, Ulltimate Rewards may also collect information about you from publicly available sources such as company registers. Ulltimate Rewards may also collect personal information (including sensitive personal information) (which includes any relevant transaction data and account identifier data) from your financial services provider. For the purpose of this Privacy Policy:

Personal information: Means any information about an identified or identifiable Individual. Personal Information can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.
Sensitive personal information: Personal information relating to an Individual's place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.

If you give us personal information about another person, you represent that you are authorised to do so and agree to inform that person who we are, that we will use and disclose that information for the relevant purposes set out below and that they can access the information we hold about them.

Ulltimate Rewards maintains records of all transactions and activities on accounts you have with Ulltimate Rewards, including details of contracts traded and margin calls made. During the course of your relationship with Ulltimate Rewards, we will also gather information about products and services provided to you.

Telephone Conversations

Ulltimate Rewards may record telephone conversations between you and persons working for Ulltimate Rewards. Such recordings, or transcripts from such recordings, may be used to resolve any dispute between you and Ulltimate Rewards.

Cookies and our cookie policy

Ulltimate Rewards uses cookies to gather information about your access to this website, the Ulltimate Rewards application and other services we provide to you. Cookies are small pieces of information, which use a unique identification tag and are stored on your device because of you using this website or other service we provide to you.

They enhance your browsing experience in various ways, which include remembering your preference settings, displaying relevant content and ensuring web pages function as intended. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

Use of the information by Ulltimate Rewards

The information requested in any application to open an account completed by customers is required to enable us to provide a service to you. That information, together with the information collected and maintained by Ulltimate Rewards during the course of our relationship with you, is used to manage and administer the products and services provided to you. It is also used to keep you updated whilst you are a customer in relation to various matters including the contracts you have traded, your margin obligations, the funds in your account, and other activities of Ulltimate Rewards.

We may also use your personal information, including market research, analysis and developing statistics across Ulltimate Rewards Group, to develop an understanding of the products and services that you may be interested in obtaining from Ulltimate Rewards and to market such products and services to you.

We may also use it to carry out marketing and send communications, including by email, post, text, newsletter, banner advertising and other forms of communication including social media campaigns. We may analyse your personal information, as well as your trading activity, so that we can offer a more relevant, tailored service and product offering to you.

Ulltimate Rewards may share your personal information with:

Entities in the Ulltimate Rewards Group to develop an understanding of the products and services that you may be interested in obtaining from Ulltimate Rewards Group and for other legitimate business purposes;
Regulatory and government bodies from time to time and other bodies from time to time in and other, or as otherwise required by law;
any court or tribunal;
Financial institutions and other similar organisations that we deal with in the course of our corporate activities or those that are nominated by you;
Fraud prevention and law enforcement agencies if false or inaccurate information is provided and fraud is identified;
Anyone else where we have your consent or where we have another lawful basis for doing so;
An introducing broker if you were introduced to Ulltimate Rewards by an introducing broker;
External service providers and professional advisers (which may be located overseas) that provide services to Ulltimate Rewards, including credit reference agencies;
Any organisation at your request or any persons acting on your behalf, including your financial adviser, broker, solicitor or accountant;
Any third-party service providers where this is necessary to process a transaction or provide services which you have requested (e.g. software providers);
Any authority to whom Ulltimate Rewards is required to disclose such information by law;
Other financial institutions for the prevention and detection of financial crime, including fraud, money laundering, and terrorism financing; or
Other parties connected with your account (e.g. other people named on the application).

How we protect your information

Ulltimate Rewards is committed to protecting the privacy of all personal information that Ulltimate Rewards obtains from you.

We continue to adopt industry and information security best practices to protect your personal information and ensure that unauthorised persons do not access it. Measures include encryption of data during transmission, strong authentication mechanisms, cybersecurity processes and secure access to machines and data.

We train our employees who handle personal information to respect the confidentiality of customer data and the privacy of individuals.

What are your rights?

You need not give us any of the personal information requested by Ulltimate Rewards. However, without that information Ulltimate Rewards will not be able to open an account for you where the information is requested in an application form, or to provide you with any other services, information or assistance you have sought.

Your rights are as follows in respect of the personal information we hold about you:

The right to be informed about processing of your personal data;
The right to have your personal data corrected if it's inaccurate and to have incomplete personal data completed;
The right to object to processing of your personal data;
The right to restrict processing of your personal data;
The right to have your personal data erased (the "right to be forgotten");
The right to request access to a copy of your personal data and information about how we process it. Please make all requests to our Bermuda office for access by emailing support@ulltimaterewards.com; and
The right to move, copy or transfer your personal data ("data portability").

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request. We will stop processing your personal data unless the processing is for the establishment, exercise or defence of legal claims or we have a legitimate business purpose or legal grounds for the processing.

Where applicable, requests made to Ulltimate Rewards will be addressed within 45 days from the day we receive the request. This time period may be extended by no more than 30 days if there is a considerable amount of personal information requested and the request would interfere with the operations of Ulltimate Rewards, or if the request requires more time to liaise with an overseas third party. We will advise you of the extension, where applicable.

You are only entitled to your own personal information and certain information about the data, but not to information relating to other people, unless the information is also about them or they are acting in a legal capacity on behalf of someone else.

Please contact us if you have any questions or complaints about your privacy. Email: support@ulltimaterewards.com.

If a complaint is not resolved by Ulltimate Rewards to your satisfaction, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

Receiving commercial electronic messages

With your consent, we may send marketing and/or promotional messages to any electronic address that you provide or for which you are responsible. You warrant that you have authority, either as or on behalf of the electronic account holder, to provide this consent and agree that until you withdraw your consent by providing written notice to us or using an unsubscribe facility in the message, we may continue to send commercial electronic messages to those addresses.

Amendments to this Privacy Policy

Ulltimate Rewards may make change this Privacy Policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this Privacy Policy periodically so you are aware of any changes. By using our services, you agree to this Privacy Policy.