Privacy Policy

v1.0 22nd July 2020

OTC Direct Markets Limited (“OTCDML”) is committed to protecting your privacy.

This Policy explains how we collect, use and handle any personal data we collect from you when (i) you use our website (the“Website”) and/or (ii) we provide services to you via the OTC Direct trading platform. Please also refer to our Cookie Policy (see Appendix 1 below) which explains the use of cookies and other web tracking devices via our Website.

Please read the following carefully to understand our Policy regarding your personal data and how we will treat it. By visiting the Website or by using our Services you are accepting and consenting to the practices described in this Policy. We will commit to the protection and privacy of any shared personal information by meeting the aims and objectives of the principles of the General Data Protection Regulation 2018 (GDPR).

Who is responsible for your personal data?

OTC Direct Markets Limited is responsible for your personal data. 

What is personal data?

We collect information about you in arrange of forms, including personal data. As used in this Policy, “personal data” has the meaning given to it in the GDPR, and includes any information which, either alone or in combination with other information we hold about you,identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

How does OTCDML collect your personal data?

We may collect and process personal data about you or relating to you in the following ways:

·      if you register to become a client of our Services;

·      if you send us a message through our Services or correspond with us by telephone in writing or otherwise;

·      administering and operating your account;

·      as you visit web pages on our Website; and

·      from any of your activities in connection with your use of our Services.

We will at all times minimise the collection and use of personal data to what is necessary to administer our business and deliver ourServices to you. In order to process your requests and transactions we will uset he information provided by you. To serve you better, we may combine information you give us through various channels.

With regard to each of your visits to our Website, we may automatically collect the following information:

·      technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, your ISP and/or mobile carrier, browser plug-in types and versions, operating system and platform, your location (if you are accessing the Services from a mobile device(note that most mobile devices will allow you to prevent location data from being sent to us));

·      information about your visits, including the full Uniform Resource Locators (URLs) to, through and from which you access our service (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page.

For which purposes will we use your personal data

We will only process your personal data when we have specific purpose and lawful reasons to do so.

We may process your personal data on one or more of the following legal grounds:

·      because processing is necessary for the performance of our Services to you under the contract with you or your organisation;

·      To comply with our legal and regulatory obligations;

·      because processing is necessary for the purpose of our legitimate interests.

In addition, the processing may be based on your consent where you have expressly given that to us. This will be the case for all users of the OTC Direct Trading Platform.

Where we rely on legitimate interests as a lawful basis to process your personal data, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.If you want further information on the balancing test we have carried out, youcan request this from our Data Protection Officer .

We may use your personal data for the following purposes:

·      Providing our Services to you as requested by you or your organisation;

·      Administering your account with OTCDML;

·      Protecting the security of and managing access to our premises, IT and communication systems, online platforms, Websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities,

·      Compliance with our legal obligations (such as record keeping obligations), compliance screening or recording obligations(e.g. for anti-money laundering, financial and credit checks and fraud and crime prevention and detection purposes);

·      For monitoring and assessing compliance with our internal policies and standards;

·      To identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;

·      To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;

·      To comply with court orders and exercises and/or defend our legal rights; and

·      For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided tocus.

With whom will we share your personal data?

As part of delivering our Services to you, we may provide third parties access to personal data. We will use reasonable endeavours to ensure that those third parties only use your personal data consistently with this Policy and the requirements of the GDPR.

We may share your personal data in the following circumstances:

·      we may share your personal data between the OTCDML group companies on a confidential basis where required for the purposes of providing the Services to you and for administrative, billing and other business purposes;

·      We may share your data with any third party to whom we assign or novate any of our rights or obligations;

·      We may also instruct third party service providers to process personal data on our behalf and in accordance with our instructions. We will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;

·      We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.

Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Processing of your personal data by outside theEEA

OTCDML is a global online commodities trading platform. We may transfer your personal data abroad in connection with the provision of Services to you.

This may include countries outside the European Economic Area which do not provide the same level of protection as the laws of the European Economic Area.  We will ensure that such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR.

Keeping your personal data secure

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data.  Personal data may be kept on our systems or in paper files.  Our employees respect your privacy and are required to safeguard your personal data pursuant to the terms of their employment contracts with OTDML.

Your rights

Subject to certain legal conditions, you have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected, object to or restrict us using your personal data or have your personal data erased (Right to be forgotten). You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to do any of the above, please send an email to . We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.

We will consider any requests or complaints which we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may lodge complaint about our processing of your personal data with the office of the information commissioner (

For how long do we retain your personal data?

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Policy or until you withdraw your consent and we are not legally required or otherwise permitted to continue storing such data. 

Updating personal data about you

If any of the personal data you have provided to us changes,for example if you changed your email address, or if you become aware that we have any inaccurate personal data about you, please let us know by sending an email to We will not be responsible for any losses arising from incomplete, inaccurate,inauthentic or deficient personal data that you have provided to us.

 Updates to this Policy

This Policy was last updated in July 2020. We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the updated Policy onthe Website or publish it otherwise. The changes will take effect as soon as they are posted on the Website.


If you have any questions or concerns, please contact our Data Protection Officer (DPO) by emailing 


APPENDIX 1 – Cookie Policy


What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Website.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognise your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers on our Website, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

Cookies we use

Our Website uses the following types of cookies for the purposes set out below:

Essential Cookies | These cookies are essential to provide you with Services available through our Website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Website and help the content of the pages you request load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those Services.

Functionality Cookies | These cookies allow our Website to remember choices you make when you use our Website, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Website which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Website.

Analytics and Performance Cookies |These cookies are used to collect information about traffic to our Website and how users use our Website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Website, the websites that referred them to our Website, the pages they visited on our Website, what time of day they visited our Website, whether they have visited our Website before, and other similar information. We use this information to help operate our Website more efficiently, to gather broad demographic information and to monitor the level of activity on our Website.

Social Media Cookies | These cookies are used when you share information using a social media sharing button or “like” button on [our Website/Application(s)/Services] or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser(usually located within the “settings,” “help” “tools” or “edit”facility).  Many browsers are set to accept cookies until you change your settings. 

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and

Updates to this Cookie Policy

This Cookie Policy was last updated in February 2018. We reserve the right to update and change this Cookie Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements.