Purpose & Scope
First Exchange Ltd, its affiliates and subsidiaries place a priority on the Data Privacy of its employees, contractors, clients, prospective clients, service providers and other partners or third parties and on the importance of compliance with Data Protection
and Privacy laws worldwide. Thus, First Exchange Ltd has developed this Policy that outlines and explains the appropriate principles concerning collecting, processing, transferring and using an individual's Personal Data during
In its collection, use and disclosure of Personal Data, First Exchange Ltd strives to balance the needs of managing its business effectively while minimising intrusiveness and complying with local legal requirements. In some countries, additional requirements
beyond this policy may be applied to comply with local legislation. Data Protection and Privacy has been and will continue to be an integral component of First Exchange Ltd's business practices.
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- Employment records maintenance
- Employee performance reviews and ranking processes
- Wage/stock option planning and administration
- Training administration
- Employment terminations
- Performance reviews and disciplinary records
- Headcount planning and reporting
- Background checks and drug testing
- Expense management
- Pension administration
- Health administration
- Health insurance/benefits
- Information on the Company group's intranet that is needed to facilitate communication between employees within the Company's group
- Equal opportunities monitoring
- Any requirement by law (statute, regulation or court ruling) or contract to which the individual is a party; a response to administrative or judicial process, including a subpoena, search warrant or garnishment of wages
- Cooperation with governmental agencies or law enforcement, to the extent required by local law
- An emergency, which is reasonably believed by First Exchange Ltd to pose a risk of harm to person or property or the business interest of First Exchange Ltd
- Managing, maintaining and developing business relationships with clients, prospective clients, service providers and other partners or third parties, including but not limited to business development and marketing
- Processing by First Exchange Ltd and its employees of Personal Data held on behalf of clients
- Any additional functions or duties of First Exchange Ltd in connection with the proper conduct of First Exchange Ltd's business
Data Protection & Privacy Principles
The Data Protection and Privacy principles below are the foundation of this Policy. As such, First Exchange Ltd will, through appropriate management and controls on an ongoing basis, monitor implementation of and compliance with these principles. It shall
be a fundamental principle with First Exchange Ltd that any Personal Data shall be processed fairly, sensitively, respectfully and in accordance with this Policy and applicable local law.
1) Notice: First Exchange Ltd will inform individuals about the purpose for which it collects Personal Data, how to contact First Exchange Ltd with inquiries or complaints, and the administrative process by
which the complaints will be resolved. Where appropriate, First Exchange Ltd will communicate the types of third parties to which First Exchange Ltd discloses Personal Data, and the choices, procedures and means First Exchange
Ltd offers for limiting use and disclosure of personal information will also be provided.
2) Choice: Subject to applicable local law and First Exchange Ltd policies, general procedures and business requirements First Exchange Ltd will ensure that the rights of Data Subjects, about whom Personal
Data is held, can be fully exercised. This includes the right of an individual to choose how their Personal Data provided is used, whether the use of such data is incompatible with the original purpose or authorizations, or
is disclosed to third parties, subject to laws requiring disclosure and consent.
3) Onward Transfer: First Exchange Ltd will ensure that all transfers of Personal Data, whether within or outside of the First Exchange Ltd group, are protected by suitable safeguards and in accordance with
applicable local law. Further, unless required by court or another legal mandate, or except as discussed below, Personal Data will only be transferred outside of First Exchange Ltd if the receiving party has entered into a
Data Protection Agreement with First Exchange Ltd or comparable safeguards are in place. Where Personal Data is transferred outside of First Exchange Ltd, First Exchange Ltd will ensure that any such transfer protects the legitimate
interests of Data Subjects in line with this Policy and applicable local law.
4) Security: First Exchange Ltd is committed to protecting Personal Data against unauthorized use or disclosure. To ensure the appropriate use of Personal Data, and prevent unauthorized access to such Personal
Data, as well as prevent loss, alteration or destruction of Personal Data. In adherence with Data Protection and Privacy laws worldwide and internal First Exchange Ltd policies, First Exchange Ltd will address security at all
appropriate technology infrastructure points.
5) Data Integrity: First Exchange Ltd will collect and process appropriate Personal Data only to the extent that there is a Business Need for Personal Data, to fulfill operational needs, and/or to comply with
legal requirements, including those legal requirements of the countries in which the Personal Data was collected, as applicable. First Exchange Ltd will take reasonable steps to ensure that all Personal Data is relevant, accurate,
complete, current, and reliable for its intended use. All Data Subjects have a responsibility to assist First Exchange Ltd in this effort.
6) Data Retention: First Exchange Ltd will not keep Personal Data for longer than is necessary for the purpose or purposes, for which it was intended, or as required by contractual agreement, by law or regulation,
by other First Exchange Ltd policies or, where applicable, for the appropriate statute of limitations period.
7) Access: Upon request, First Exchange Ltd will provide individuals with access to their Personal Data and, when appropriate, allow the individuals to request that their Personal Data be corrected or updated
by First Exchange Ltd, as required by law or First Exchange Ltd policies.
8) Enforcement & Oversight: First Exchange Ltd will address complaints or disputes regarding Personal Data promptly, in an orderly fashion and courteously. First Exchange Ltd will provide or, where appropriate,
endeavor to provide notification to Data Subjects about how to file a complaint or inquiry and the administrative process to follow. First Exchange Ltd will perform a self-assessment on a regular basis to verify that this Policy
is communicated, prominently displayed, implemented, and accessible. First Exchange Ltd will cooperate with the relevant Data Protection Authorities in the investigation and resolution of complaints relating to this Policy.
First Exchange Ltd will seek, in a timely manner as practicable, to comply in good faith with the advice of these authorities.
9) Training & Audit: First Exchange Ltd will provide appropriate training to all relevant staff handling and dealing with the Processing of Personal Data so that any such processing will be carried out in accordance
with this Policy and applicable law. First Exchange Ltd will further ensure that Data Protection and Privacy is subject to periodic audit.
Transferring Your Data Outside The "EEA"
We may transfer your data outside the European Economic Area (the "EEA").
Some of those countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection.
Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example,
ensuring that the organisation receiving the data is registered with the EU-US Privacy Shield (in the case of transfers to the USA), or that we use the EU's model contractual clauses.
First Exchange Ltd entities and all non-First Exchange Ltd entities (e.g., agents, contractors, outsource service providers and processors) accessing or processing Personal Data are required to comply with this Policy with respect to such Personal Data.
The Data Officer is primarily responsible for adopting, implementing, and maintaining this Policy.
The responsibility for the implementation of the Policy lies with every employee and manager, whether the Personal Data is in the form of manual records, computer data or arises from communication with employees and Data Subjects both online (electronic)
or off line (manual records). Implementation requirements will include the development of notice and consent forms to provide to managers and Data Subjects where required by applicable laws.
Employees, agents, contractors and their employees are individually responsible for providing/maintaining accurate information and for protecting the personal information that First Exchange Ltd has about any individual in support of the implementation
of this Policy. Employees who violate this Policy or applicable legal requirements are subject to discipline, up to and including termination of employment, dependent on the severity of the violation. Agents or contractors
or their employees who violate this Policy or applicable legal requirements are subject to termination and/or other contractual penalties. Employees, agents and contractors should also be aware that if they knowingly or recklessly
obtain or divulge Personal Data without First Exchange Ltd consent, they may be committing a criminal offence.
Data Privacy Investigation & Dispute Resolution
Human Resources will address any complaints or disputes regarding Personal Data promptly and courteously, and will follow all applicable laws to respond to the complaint. This includes inquiries from Data Subjects, employee councils, management sponsors,
or regulatory authorities.
A responsible person designated by management will handle investigations regarding non-compliance with this Policy. All investigations will be handled under the legal requirements of the geographic area where the investigation is taking place.
Access To Personal Data
The Data Officer is responsible for maintaining and safeguarding Personal Data, and for ensuring that access to such Personal Data is restricted to persons who have a job-related "need to know" or who have documented access rights. Covered entities may
have access to Personal Data on a business related need to know for purposes generally compatible with the collection of the Personal Data.
Data Subjects may review the contents of any files as requested pursuant to the access principles detailed above and subject to other First Exchange Ltd policies. All Data Subjects must authenticate themselves based on online or offline standards (i.e.,
pass codes) set by First Exchange Ltd before gaining access. Data Subject may request a copy of documents, but under no circumstances will an individual be allowed to remove any documents from the file or be allowed to remove
the original file from First Exchange Ltd. Certain confidential files, such as investigative files, will not be accessible to Data Subjects, in particular employees.
Verification Of Employment
Regarding any requests for information concerning an First Exchange Ltd employee's status which may be received from non- First Exchange Ltd entities, only members of the human resources department are authorized to release any information and this will
be restricted to confirmation of current employment including the employee's name, the most recent job title and the dates of First Exchange Ltd employment. Additional information will not be provided without the employee's
Use Of Universal Analytics (Google)
- _gat_ UA 112356073-1
Purpose: These cookies collect information about how visitors use our website. We use the information to compile reports and to make improvements. The cookies collect information in an anonymous form, including
where visitors have come to the website from and the pages they visited.
If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at email@example.com
Changes To Policy
First Exchange Ltd may from time to time amend this Policy to reflect changes in any applicable legislation. First Exchange Ltd will notify Data Subjects of such amendments as soon as reasonably practicable.