Privacy is of utmost importance to Hummingbird Trading, LTD ("Hummingbird"). It is our policy to respect the confidentiality of information and the privacy of individuals. The data we protect are the "Personal Data" which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting the privacy and the confidentiality of Personal Data a fundamental component of the way we do business. We are also bound by principles contained in the EU General Data Protection Regulation (GDPR).
In this Policy, "Services" means the Hummingbird website, any feature provided by us via the website or any local application (mobile, desktop or otherwise).
This Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. You should check this page from time to time to ensure that you are happy with any changes. Any information held will be governed by our most current Policy.
This Policy was last updated on May 25, 2018.
INFORMATION WE COLLECT FROM YOU
Information you provide us:
- When you sign-up for Hummingbird’s Services we may collect the following personal data from you: email address, Facebook ID (for Facebook Connect), your date of birth, your country of residence, your first name, your family name.
- When you complete your Account Validation for Live Trading, we may collect the additional personal data as follows: residential address, your employer name, your annual income, your personal wealth, your source of wealth, your trading experience, previous bankruptcies and financial convictions. We may also ask you to upload a scanned copy of your ID and a proof of residence document (i.e. a bank statement or utility bill).
- For payment services we may collect additional information such as your mobile phone number, your personal BTC address or other cryptocurrency address.
- Other personal information you may provide includes a profile picture and a trader name (pseudonym).
- If you contact us, we may keep a record of that correspondence.
Information we collect automatically:
When you sign-up for or use the Hummingbird Services we may automatically collect the information as follows:
- Log information: We log technical information about your use of the Services, including the type of browser and version you use, last access time, initial Internet Protocol (IP) address and last used Internet Protocol address.
- Device information: We collect information about the mobile device you use to access our mobile application including the hardware model, operating system and version, unique device identifiers and mobile network.
- Event tracking: We collect navigation data and information about technical errors.
Information we collect from other sources:
We also receive information from other sources and combine that information with information we collect through our Services. For instance:
- When you log-in to our Services via a third-party, social media service (Facebook), we collect information about your social media account in accordance with the authorization procedures determined by such social media services.
- Our Website uses “cookies” to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Website. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Information generated by using our services:
As you use Hummingbird’s Services you will generate information which is directly associated with your account and use of the Services:
- Your historic trading record and information about any trades from the point you start reporting them to us.
- Details of transactions you carry out through our Services.
HOW WE USE YOUR PERSONAL INFORMATION
How we use the personal information you provided us
The personal information you provided us is used for the purposes as follows: authentication, KYC and AML compliance, operational management, customer support, payment services and communication.
- Authentication: information collected at signup which allows you to access the Hummingbird Trading platform (i.e. log into our website or mobile app), as well as for communicating with our customer support. For this purpose we collect your email address or Facebook ID (when using Facebook to create your account). You may also be asked to provide a password, however, your password remains encrypted in our system and cannot be viewed by anyone but you.
- KYC and AML compliance: KYC (Know Your Customer) and AML (Anti-Money Laundering) information is information that you provide us in order for us to legally process all monetary transactions. For this we collect your first name, family name, date of birth, country of residence, and residential address. We will also ask you to submit a scan of your ID and a valid proof of residence (i.e. a bank statement or utility bill) which we use to verify that the information provided is accurate.
We may also collect additional information about your employer, annual income, personal wealth, trading experience, if you own or work in a brokerage, declared bankruptcy or have had a prior financial conviction. This information helps us to ensure that you are eligible to use our Services.
- Operational management: you will be asked to provide us information that also allows us to efficiently operate our Services. This information includes an optional profile pic, which you uploaded onto our platform, a trader name (created by you at signup) which is publicly visible on our website and mobile application, a referral code linked to the person who told you about Hummingbird Trading.
- Customer support: in order to answer any questions you may have regarding our Services, we will use any or all of the information at our disposal in order to accurately meet your support needs. This includes information you provided as well automatically collected information, and information generated by your use of our Services.
- Payment services: we may ask you to supply us with additional information such as your mobile phone number in order for you to use certain payment services. We may also require you to provide us with your personal BTC address or other cryptocurrency address in order to complete a transaction.
- Communication: you may provide us with your email address and unique device ID to which you may opt-in to receive content provided by Hummingbird. Please note: we distinguish between two forms of communication: transactional communication and marketing communication. Transactional communication are receipts for a transaction initiated by you via our Services (i.e. confirmation of a document received). Marketing communication covers all communications initiated by Hummingbird for the purposes of marketing our Services. You will have the option to opt-out of marketing communications at any time by clicking on the “unsubscribe” button or by disabling push notifications.
How we use information we collect automatically
When you use our Services, we may automatically collect information from you for the following purposes: user experience, bug tracking, communication, compliance and fraud prevention.
- Log information: This information is used to help resolve technical issues, and is also taken into account for identifying potential fraudulent activity and to protect your account (i.e. a sudden IP address change). The use of IP data also allows us to ensure that the Services offered correspond to those available in your local jurisdiction.
- Device Information: This information allows our technical team to ensure that the Services work accurately on your device. This information is also used to identify potential fraudulent activity and to protect your account.
- Event Tracking: we use third-party event tracking software to track all events (Adjust & Bugsnag) within our platform. Event tracking allows us to identify and log technical errors, and to optimize our services for better ease of use. This information is anonymized and is not tied to any particular individual.
We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you. So far as we are able we shall ensure that all of your Personal Data is accurate and up to date.
DISCLOSURE OF PERSONAL DATA
We share your information with selected recipients to perform functions on our behalf. All such third parties will be contractually bound to protect data in compliance with our Policy. The categories of recipients include:
- Companies within the Hummingbird Trading corporate family, in order to provide the Services to you.
- SMS providers, like Twilio, located in the United States, to provide SMS services.
- Email providers, like Mailchimp, located in the United States, or Elastic Email, located in Canada, to provide email services.
- Cloud services providers, like Amazon, located in the United States, to store certain personal data and for disaster recovery services, as well as for the performance of any contract we enter into with you.
- Payment service providers, like Neteller, located in the UK, our banks, located in the USA, EU and Singapore, or our credit card processor, located in the EU, who may require additional information to authenticate a transaction initiated by you (i.e. your postal code, mobile telephone number, or any other Personal Data you provided).
We also may share personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Hummingbird Trading’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Hummingbird is among the assets transferred.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of Hummingbird Trading, LTD , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
LEGAL BASIS FOR PROCESSING
We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services, website and mobile apps; and for our marketing activities.
SECURITY OF YOUR PERSONAL DATA
We protect Personal Data with appropriate physical, technological and organizational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means whereby information is conveyed from location to location. As such we cannot give any warranty or assurance that the means where information is conveyed to us are safe, reliable or have integrity. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of Hummingbird is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorized alteration of the information under our control. More specifically, our server uses SSL (Secure Sockets Layer) security protection by encrypting your Personal Data to prevent individuals from reading these Data as they travel over the Internet.
STORAGE OF PERSONAL DATA
All information you provide to us is stored on secure servers within the United States of America, with providers that comply with the US-EU Safe Harbour Framework, as set forth by the U.S. Department of Commerce. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our website or mobile application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The privacy and confidentiality of your personal information is of fundamental importance to us. We take all appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data and personal information.
We restrict access to personal information to employees, contractors and agents in order to operate, develop or improve our services.
You may have the following data protection rights:
- To access, correct, update or request deletion of your Personal Information. Hummingbird takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at firstname.lastname@example.org. We will consider your request in accordance with applicable laws.
- In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information - meaning that you can obtain a copy of your data in a commonly used electronic format so that you can manage and move it. Again, you can exercise these rights by emailing us at email@example.com.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.
By using the Services, you signify your agreement to this Policy. Hummingbird reserves the right to change this Policy at any time. If we make any material changes to this Policy the revised Policy will be posted here, so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. Please check this page frequently to see any updates or changes to this Policy.
QUESTIONS AND COMPLAINTS
Any questions about this policy, the collection, use and disclosure of Personal Data by Hummingbird or access to your Personal Data which is required by law (or would be so subject had the storage in question taken place in a relevant EU member state if the case may be but not otherwise) to be disclosed should be directed to firstname.lastname@example.org.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the country in which you live or work where you think we have infringed data protection laws.