Last updated 01 August 2023
This privacy notice explains how we, the LEXMT Group (ADSS), process your personal information when you use our services such as our website, app, content and features, or otherwise engage with us online or offline.
The LEXMT entity responsible for your personal information is the one you have approached to provide services to you in your region.
This notice applies across all our regions. However, individuals in the United Kingdom (UK) should also read the “For UK Individuals” section and individuals in the United Arab Emirates (UAE) should read the “For UAE Individuals” section.
If you are under 18 years old (UK) or under 21 years old (UAE), you must not access our services. Our core services involve financial risk-taking and are neither suitable nor intended for those underage.
If you have any question about your data protection rights or if you do not understand anything explained in this notice, please contact us by email to [email protected] (UK) [email protected] (UAE).
This notice applies to:
Our users who access our website, app, content, features or other online services;
Our prospective customers identified as such by us or our third parties;
Our registered users who are our customers;
Our suppliers and business partners;
Our job applicants; and
Anyone else who interacts with us, when you call, email or visit us or otherwise interact with us.
This notice applies to you if you act in your personal capacity, for example, as our customer, and if you act in your professional capacity, for example, as an employee or agent of our supplier.
Generally, “personal information” means any information that identifies you or relates to you, except for anonymised information that cannot reasonably be linked back to you.
Personal information will include your name, login details, transaction details, payment details, the details of your enquiry and other information that is obviously about you. However, it may also include technical device, browser or app data, such as your IP address, your movement on the website, information about how you engage with our services and similar information. Based on your online visits, we may observe or infer information about your preferred content, features, trading style and other interests, even without you telling us. For more on personal information, please see the categories of personal information below.
You can exercise your rights in relation to all personal information about you as set out below.
The document below explains what personal information is necessary for each purpose. We keep our processes and data collection under review and will update this notice should any personal information no longer be necessary for the given purpose.
Where required in connection with the purposes set out above, we will share your personal information with third parties where it is necessary, proportionate and lawful, including with:
Our third parties that provide services or advice to us;
Our marketing, advertising and analytics partners including Google, Adobe, Facebook, Salesforce and others;
App stores operated by Google, Apple, Amazon and others who distribute our app or content;
Our affiliated companies;
Your agent such as a broker or advisor who interacts with us on your behalf;
Third parties who provide additional services, features or content to you;
Tax, regulatory and other authorities to comply with our legal obligations or best practice;
Credit reference, anti-fraud agencies, law enforcement and other stakeholders;
Persons or authorities where we are compelled by law, responsible practices or for legal claims;
The relevant entity in case of a merger, acquisition or collaboration; and
Other third parties where you have provided your consent.
Our services may contain links to other websites, third party services, such as Twitter, Facebook, LinkedIn, Instagram, YouTube and plugins. Some of the third parties who we share your personal information with, such as credit reference agencies, payment services providers or public authorities, process your personal information for their own purposes.
You should check the privacy statements of these third parties and we are not responsible for how they may process your personal information. Some of our third party service providers may use your anonymised personal information for business administration and product development purposes.
We will keep your personal information for as long as is necessary for the purposes listed above or longer, as may be required by law or for legal claims. You may contact us for further details or request deletion of your personal information at any time.
The table below illustrates what general retention periods may apply to specific categories of personal information. However, the periods may vary depending on circumstances in accordance with the law.
| Category of personal information | Retention period |
| Account details, general details, call recording data, transaction data | Up to 10 years after account closure/last interaction depending on legal and regulatory requirements |
| CCTV data | 30 days from capture |
| Device and browser details, engagement information, preferences and interests, third party data, usage data | 2 years from collection |
| Professional opportunity records | 6 years from collection |
| Payment details | Processed by our payment provider. Direct debit details will be kept for the duration of the mandate. |
| Special categories personal information | Generally, not retained or only kept for the duration of the relevant event. |
We maintain appropriate organisational and technological safeguards consistent with best international standards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of the personal information we hold.
We also seek to ensure our third-party service providers do the same. We only appoint service providers under appropriate contract who provide sufficient guarantees about data security in accordance with applicable law.
We will endeavour to use the least amount of personal information as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate.
Where appropriate, we apply security measures such as encryption or hashing when sharing your personal information with third parties.
Our staff will access your personal information on a “need to know” basis.
Depending on where you reside, your personal information will be held in the UK or the UAE, as applicable.
However, we may transfer your personal information to, or host it on systems operated by, our affiliates, suppliers, business partners and other third parties in countries different to your country of residence, including the UK, UAE, EU or US.
Each of our recipients is subject to appropriate safeguards such as due diligence and the standard contractual clauses or similar contract for international transfers of personal information.
If you would like us to stop sending you marketing communications and to process your personal information for direct marketing purposes, please contact us.
You can request to stop receiving our marketing communications at any time by clicking on the unsubscribe link at the bottom of each marketing message and we will add you to a suppression list or otherwise arrange that you no longer receive marketing communications.
| Category of personal information | Description |
| User account details | Username, password, and similar information. |
| CCTV data | Image data recorded by our CCTV. |
| Call recording data | A recording of your calls with us. |
| Details of your query | Information in your query, complaint, job application or other communication. |
| Device and browser details | Information automatically provided by your device and browser including mobile device ID, internet protocol (IP) address, cookie ID, online identifiers, operating system, browser type, language, time zone setting, location and date and time of access. |
| Engagement information | Information about your engagement with our emails and other communications or with our content on the Internet including open rates, click rates, view rates, active time spent, survey data, feedback data and similar information. |
| General details | Your name, date of birth, address, email, telephone number, email address, nationality, countries of residence, power of attorney, net income, net worth, sources of funds, PEP status, role and employer details if you are acting in your professional capacity and similar information. |
| Identity details | Your passport details, image, social insurance number, tax payer ID and similar information. |
| Professional opportunity records | Your personal and professional details as business customer and other opportunity records. |
| Payment details | Payment card, bank account details and similar information. |
| Preferences and interests | Information about your preferences and interests known, observed or inferred from various sources such as your device and browser details, engagement information, public data, third-party data, transaction data and usage data. |
| Public data | Publicly available information about you. |
| Special categories data | Except for health and safety, diversity monitoring or for other important reasons, we do not process information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. |
| Third party data | Information provided by third parties about your interaction with our posts and content and ‘likes’ on social media platforms, such as Twitter, Facebook or Instagram, your preferences and interests received from our advertising and analytics partners, your downloads or other interaction with our app or content in an app store, references from your previous employer, referees, membership organisations and other third parties. |
| Transaction data | Information about the transactions you make in our services. |
| Usage data | Information about how you navigate and engage with our online services, features including online activity data such as downloads, clickstream data with URLs visited previously, page interaction, such as scrolling, clicks, and mouse-overs, methods used to browse away from our service, search text you enter, search results returned, selected items, navigation, load event, opening ticket, news selection, login, logout, market or resting order, information in security logs and similar information. |
Our Data Protection Officer can be contacted by post to Outsourced Data Protection LLP, 71 Queen Victoria Street, London, EC4V 4AY or email to [email protected].
If we make any changes to our notice, you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree with the changes, please do not continue to use our website or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.
This section provides further disclosures and describes the rights in relation to your personal data that you may have under UK data protection law if you are an individual in the UK.
A. Controller
ADS Securities London Limited will process your personal information as “controller” for the purposes and under the legal grounds for processing set out above.
ADS Securities London Limited is authorised and regulated in the UK by the Financial Conduct Authority (FRN 577453). Registered as a company in England and Wales, number 07785265 with registered address at 125 Old Broad Street, London EC2N 1AR. VAT Registration Number: 212 722 447.
B. Personal data
“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
C. Data subject rights
Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have the following rights in relation to your personal data:
Right to information about matters set out in this notice. You may also contact us for further details about our data retention policy and international data transfers.
Right to make an access request to receive a copy of your personal information held by us.
Right to rectification of any inaccurate or incomplete personal information.
Right to withdraw consent previously provided.
Right to object to our processing of personal information based on our legitimate interests such as processing for direct marketing purposes.
Right to erasure of personal information that is no longer needed, for example, if you object to our profiling for advertising or personalisation purposes and also request erasure.
Restriction on the processing of personal information, for example, where necessary while we deal with your enquiry.
Right to human intervention in respect of any automated decision-making without human involvement that significantly affected you.
Right to data portability from one service provider to another, where applicable.
Right to lodge a complaint with the Information Commissioner’s Office.
All requests will be processed without undue delay and no later than within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.
This section provides further disclosures and describes the rights in relation to your personal data that you may have under UAE’s Federal Decree-Law No. 45 of 2021 called the Personal Data Protection Law if you are an individual in the UAE.
A. Controller
ADS Securities L.L.C. will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above.
ADS Securities LLC (“ADSS”), a limited liability company incorporated under United Arab Emirates law. Registered under Commercial License No. 1190047. ADS Securities LLC is regulated and authorised in the UAE by the Securities and Commodities Authority (SCA): registration No. 305027. Registered Office: 8th Floor, CI Tower, Corniche Road, P.O. Box 93894, Abu Dhabi, United Arab Emirates.
B. Personal Data
“Personal data” means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person.
C. Natural person’s rights
Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have the following rights in relation to your personal data:
Right to information about matters set out in this notice. You may also contact us for further details about our data retention policy and international data transfers.
Right to make an access request to receive a copy of your personal information held by us.
Right to rectification of any inaccurate or incomplete personal information.
Right to withdraw consent previously provided.
Right to object and stop our processing for direct marketing purposes including profiling and statistical surveys, any automated processing that has legal or other serious consequences on you or any processing in breach of the law.
Right to erasure of personal information that is no longer needed.
Restriction on the processing of personal information.
Right to data portability from one service provider to another, where applicable.
Right to lodge a complaint with the UAE Data Office.
All requests will be processed without undue delay as required by applicable law.
