Privacy Policy
This policy is made for and applies to anyone who visits Grey Epoch www.greyepoch.com (“Our Site”). Please read this Privacy and Cookie Policy carefully to understand our views and practices and your rights regarding your personal data, and if you don’t agree with it, then shouldn’t use our Website.
By navigating this website and clicking Accept in the Cookie button, then you confirm that you have read, understood, and agreed to this policy.
Alternatively, feel free to email us at info@greyepoch.com you have questions or concerns.
We may update our privacy policy from time to time. Any changes we make will be posted on this page and, where appropriate, and if we have an up to date email address for you on record, we will send you an email to confirm the changes as well.
Definitions
Grey Epoch, or "we", "us" or "our" means us, Grey Epoch;
"Service" or "Services" means Grey Epoch’s Website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless if the use is in connection with an account or not;
“Website” or “Site” means www.greyepoch.com;
“Agreement” means this Privacy Policy, updated from time to time as described herein;
“UK GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018;
“Data Protection Regulation” means UK Data Protection Act 2018, and the UK GDPR .
Our Contact Details and About Us
Grey Epoch Europe
Name: Grey Epoch Europe Limited
Business & contact address: 37-41 Mortimer House, Mortimer Street, London, W1T 3JH
Registered address: 40 Gracechurch Street, London, EC3V 0BT
Phone Number: +44 20 7038 7691
Grey Epoch Europe is registered with the UK Information Commissioner's Office (registration number ZB297369); the Data Protection Officer is Edmund Lehmann. You can contact Edmund by email at: info@greyepoch.com
Grey Epoch Europe Limited (FRN: 959638) is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859) which is authorised and regulated by the Financial Conduct Authority.
Grey Epoch Trading
Name: Grey Epoch Trading LLC
Business & contact address: 141 W. Jackson Suite 2270 Chicago, IL 60604
Registered address: …
Phone Number: …
Data Controller
Grey Epoch act as a Data Controller in relation to any personal data you provide to us, which means we will only process and share your data in line with the requirements of the applicable data protection laws and we will take reasonable steps to ensure that those with whom we legitimately share your data are equally robust in their approach to data protection.
Use of our Website
By using the Website or disclosing any personal information: (i) you agree that you have read and understand the terms of this Agreement, (ii) you accept and agree to be bound by the terms of this Agreement and (iii) you accept and agree to abide by all laws and regulations applicable to the subject matter of this Agreement and our which is accessible in our Website.
Personal Information We Collect
Personal information is the term we use to describe information which we collect and which can be used to personally identify someone. For example, a name, a personal address or even an IP address.
Here is a list of the types of personal data we collect:
Information you give to us (e.g. on contact forms, questionnaires)
Contact details - such as your name, address, email address, phone number, marital status, gender, job title.
Responses to surveys or promotions
Any updates to the information you provide to us
This is essential information for us to provide the best service we can to you. If you ask us to delete it, it’s possible we may no longer be able to provide our services to you.
Information we collect automatically when you visit our Website
Technical information - such as your IP addresses, domain names, the country you’re visiting from, files requested, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information on your visit - such as the full URL clickstream to, through and from our Website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We make reasonable efforts to keep this information anonymous, to protect your privacy.
Information you give us as part of contacting us on our Website, including:
Records of any conversations with you by telephone, email or other electronic communication channels – this is required by our regulatory partner, Thornbridge Investment Management.
Information we receive from other sources
Advertising networks and information providers - we work closely with advertising networks, analytics and search information providers and we sometimes receive information about you from them.
Information from other websites and services we operate and provide - where this happens, we will let you know about sharing the information internally or combining with information from the Website.
How do we use the information?
We use your information in line with Data Protection Regulation. In short, this means we only use it where we have a legal basis to do so. These are the general legal basis for which we use your information:
Consent - you have given clear consent to us to process your personal information.
Our contract - processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
Legitimate interests - processing your personal information is necessary for our legitimate interests or those of a third party.
Here are some reasons we process your personal information:
to allow you to access and use our Services;
to provide you with the information, products and services that you request from us;
for necessary for business activities, such as pursuing debts or ensuring the security of our services and Website;
to carry out statistical analysis and market research;
for marketing, advertising and promotional purposes;
for improving and maintaining our Website, preparing reports or compiling statistics in order to improve our services;
to notify you about changes to our services and to keep you informed about our fees and charges; and
with your consent only, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you.
Sharing your information
We may share your personal information with the following categories of third parties, including:
our service providers and sub-contractors, including but not limited to payment processors, suppliers of technical, analytical and support services, and cloud service providers;
companies that assist us in our marketing, advertising and promotional activities;
compliance, we may disclose your personal data where necessary to comply with regulations which apply to us, or the law;
analytics and search engine providers that assist us in the improvement and optimisation of our Website;
any third parties that you have agreed that we may share your personal information with for marketing purposes.
Our affiliate, Grey Epoch LLC
Finally, we may also disclose your personal information to third parties in certain exceptional circumstances as follows:
if we are required by any applicable law, regulation or law enforcement organisation to do so;
in order to enforce or apply our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity;
to protect the rights, property, or safety of Grey Epoch Europe Limited, our customers or other persons. This may include exchanging information with other organisations for the purposes of fraud protection and credit risk reduction;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
if Grey Epoch Europe or substantially all its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 are of a particular gender, aged under 30 and have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Transfers of information
The personal data we collect is processed at our offices and in any data processing facilities operated by the third parties. Technology businesses often use third parties to help them host their application, communicate with customers, power their emails etc. When we do this, sometimes it is necessary for us to share your data with them in order to allow these services to work. Your data is shared only when necessary and according to the safeguards and good practices detailed in this Privacy Policy.
Below is a list of the main third party providers we use:
Analytics: Google Analytics, LinkedIn Analytics
Communications: Mailchimp, Zoom, Calendly
CRM: Salesforce
International Transfer of Personal Data
Our business may require us to transfer your Personal Data to countries outside of the European Economic Area ("EEA"), outside of the UK or your country of origin, and including to countries that may not provide the same level of data protection as your home country. An example of this is the potential need to transfer your information to our parent company Grey Epoch LLC, which is based in the USA. This transfer would be made for example so that we can fulfil a contract with you, or in line with our legitimate interests.
We take reasonable steps to ensure that recipients of your Personal Data remains subject to the same standards as are set out in the Data Protection Legislation. When we share your data to a third country or territory not cover by the UK adequacy regulations, Grey Epoch Europe and the receiver of your data have entered into a contract incorporating standard data protection clauses recognised or issued in accordance with the UK data protection regime. These are known as ‘standard contractual clauses’.
By agreeing to this Privacy Policy, you recognise that your personal data may be transferred outside your country of origin, and consent to such a transfer (including outside the EEA or UK) and you acknowledge that as a result you may not enjoy the same protection of your data as if that data had not been transferred.
How long we store your data for
Recordings and electronic communication must be kept for up to 7 years (minimum 5 years) in order to comply with regulations. It is possible that we might keep data for longer, for instance, if we provide services to a customer for a period of time, we may retain that customer’s data their data to provide a service in the future.
Your choices and rights
Choices:
At any time:
You can turn off cookies in your browser settings
If you turn off cookies, you can continue to visit our website and browse its content, but our online Services might be less effective.
You can choose for us not to use your personal information for marketing
We will request your consent to do this, but you can choose to refuse your consent. If you have given your consent and want to retract it later, then you can either unsubscribe to the communications or opt out by contacting us at info@greyepoch.com
Rights:
You can contact us by email at info@greyepoch.com at any time, to request that we:
update any personal information which is out of date or incorrect;
delete any personal information which we are holding about you;
restrict the way that we process your personal information;
provide your personal information to a third party provider of services; or
provide you access to your data: The Data Protection Regulation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Regulation. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
Security of your personal information
Our responsibility to you
At Grey Epoch, we have physical, electronic and managerial procedures in place to protect and secure the information we collect. We are committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and we take all reasonable precautions to safeguard the confidentiality of personal information. Grey Epoch does not accept any responsibility or liabilities for the policies of third party websites that are linked to from our website.
Third party websites
Our Website may, from time to time, contain links to websites operated by third parties. This privacy policy only applies to the personal information that we collect through Grey Epoch’s Website and we cannot be responsible for personal information collected and stored by third party websites. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We don’t endorse or accept any responsibility for the content of those third party websites or third party terms and conditions or policies.
Contact us
Questions, comments and requests about this privacy policy or how we collect, use or store your personal information are welcomed and should be emailed to info@greyepoch.com or our data protection officer, Edmund Lehmann, ed@greyepoch.com or by writing to us at Mortimer House, 37-41 Mortimer St, London W1T 3JH.
