Privacy and policy

This privacy policy governs the collection, storage and use of personal information by us on our website www.ASMX.com. It provides you with details about how your personal information is treated, your rights to that data, and how we use that data. By accessing our website and using the ASMX Platform, you agree to this privacy policy in its entirety. If you don’t agree with this privacy policy as a whole or partially, you must not use the ASMX website or services. The following are the definitions of terms used in this privacy policy;

“ASMX”, “we”, “us” and “our” means ASMX Limited;

“ASMX Group” means ASMX Group PLC and any parent company or Subsidiary of ASMX from time to time.

“you” and “your” means a user of the website and the services provided via it;

“Subsidiary” means any subsidiary company within the meaning of section 1159 of the Companies Act 2006 or any subsidiary undertaking within the meaning of section 1162 of the Companies Act 2000

This privacy policy was last updated on the 13/06/2024.

Please check back regularly to keep informed of updates to this privacy policy.

Who we are.

ASMX Ltd is Registered in Gibraltar, company number 117218 at 6.20 World Trade Center, 6 Bayside Road, Gibraltar GX11 1AA.

We respect your right to privacy and will only process personal information you provide to us in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.

If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please do contact us on the ASMX website www.ASMX.group or via info@ASMX.group

The personal information we collect about you

(a) When you access, browse this website, submit personal information or apply to be a an investor on a regulated ASMX connected platform and while you continue to be a member of that platform we will collect information from you which will include;

(i) your name;

(ii) your current and previous postal addresses;

(iii) your phone, fax and e-mail details;

(vi) your passwords and security question answers;

(vii) comments you make on blogs and discussion forums on the website;

(viii) correspondence with us by email and post;

(x) data about your activities using ASMX.

(b) If you give us false or inaccurate information and we suspect or identify fraud, we will record this.

(c) If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention agencies.

Law enforcement agencies may access and use this information.

(d) We may also collect anonymised data in order to analyse statistics for usage of the site, however this data will not carry any single user identification.

2.2 How we may store, use and disclose your information.

(a) ASMX, third party data processors, agents and sub-contractors acting on our behalf, may collect, store and use your personal information for the following purposes:

(i) to authenticate and verify your identity and detect crime including money laundering;

(iii) to identify any fraud being committed;

(iv) to carry out statistical and market research;

(vi) to develop and improve our services and products;

(vii) to make this website available to you and to identify the products and services which you may be interested in;

(b) Any or all of the processes above may be automated.

(c) We may disclose your personal information as follows:

(i) to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition; and

(ii) where we are required to do so by applicable law, by a governmental body, law enforcement agency or regulatory agency.

(v) to any member of the ASMX Group of companies for the purposes of providing and administering the ASMX services.

(d) We will not sell your data, rent your personal information unless you have specifically consented to the use of that data. If you do consent and later change your mind, contact us immediately and we will cease any such activity as soon as we are informed.

How we may store, use and disclose information provided to us about third parties

We may use information you or your agent provide to us about directors/business partners and shareholders of your business to verify their identity. We may also disclose information about your business partners and shareholders to credit reference agencies so you must be sure that you have their agreement to do this. Information on shareholders who are beneficial owners will be used and supplied to others only for the purpose of the performance of identity checks and with their specific consent.

Agent specific information

If you are applying to be a member of ASMX as an agent for issuers then this section explains the type of personal information we collect about you and how we may store, use and disclose your information.

The personal information we collect about you

(a)    When you access, browse the website (including when you submit personal information to us through data entry fields on the website) or apply to be a member of ASMX as an agent, and whilst you continue to be a member of ASMX, we will collect information from you, which will include the following information:

(i) your name and your business name;

(ii) your current and previous home postal addresses;

(iii) your business postal address;

(iv) your business phone, fax and e-mail details;

(v) your business bank or building society account details;

(vi) your date of birth;

(vii) your passwords and security question answers;

(viii) comments you make on blogs and discussion forums on the website;

(ix) correspondence with us by email and post;

(x) answers to questions required by ID3 Global for identification purposes

(xi) information provided in your application form; and

(xii) data about your activities using ASMX.

(b) If you give us false or inaccurate information and we suspect or identify fraud, we will record this.

(c) If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.

Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

– checking details on applications for credit and credit related or other facilities

– managing credit and credit related accounts or facilities

– recovering debt

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

(d) We may also collect anonymised details about visitors to the website for the purposes of aggregate statistics or reporting purposes and to calculate referral fees. However, no single individual will be identifiable from the anonymised details we collect or disclose for these purposes.

(e) We will check information about you held on our own records and also obtain information from credit reference agencies about you and your business partners’ personal credit behaviour and personal credit accounts if you are proprietors of a small business and are directors of that business, your business accounts, identity information on beneficial owners of the business, your personal financial partner’s personal accounts (if they are a director).

(f) We will also search at fraud prevention agencies for information on your business, you, your business partners, beneficial owners and your addresses.

How we may store, use and disclose your information

(a) We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information for the following purposes:

(i) to assess your creditworthiness;

(ii) to verify your identity in order to prevent and detect crime and money laundering, including by using scoring methods;

(iii) to manage your ASMX agent account with us and update the records we hold about you from time to time;

(iv) to identify fraud;

(v) to carry out statistical analysis and market research;

(vi) to carry out regulatory checks;

(vii) to develop and improve our services and products;

(viii) to make this website available to you and to identify the products and services which you may be interested in;

(ix) where you have given us your consent, to contact you (including by SMS and e-mail) with products and services which we think may interest you; and

(b) Any or all of the processes above may be automated.

(c) We may disclose your personal information as follows:

(i) to credit reference agencies who will record information about your business, you and your business partners;

(ii) to credit reference and fraud prevention agencies, where it will be recorded by them, and supplied to other organisations to perform similar checks;

(iii) to and via an organisation which provides a centralised matching service which it collects from mortgage and/or credit applications, for the purpose of preventing and detecting fraud;

(iv) to other members of ASMX if required to enforce any contract that you may have facilitated to put in place for an issuer;

(v) to any member of the ASMX Group for the purposes of providing and administering the ASMX Exlayr Technology and services.

(vi) to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition; and

(vii) where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

(d)  We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

How we may store, use and disclose information provided to us about third parties

We may use information you provide to us about directors/business partners and shareholders of your business to verify their identity. We may also disclose information about your business partners and shareholders to credit reference agencies so you must be sure that you have their agreement to do this. Information on shareholders who are beneficial owners will be used and supplied to others only for the purpose of the performance of identity checks and with their specific consent.

For details of how we may store, use and disclose information which you provide in relation to borrowers on whose behalf you make loan applications, please refer to section 3 above. You must provide a copy of this privacy policy to any potential borrowers whom you represent. You must ensure that they are made aware of the content of section 3 above and that they give their consent to their information being used in accordance with this privacy policy before you provide any information about the borrower to us.

Cookies

This website uses cookies to collect information about you. If you use this website, then you accept that we can use the cookies set out below.

What are cookies?

Cookies are small data files which are placed on your computer by this website and which collect certain personal information about you.

Why do we use cookies?

Cookies enable us to tailor our service offering (including the website) and to provide you with a better service.

What cookies do we use?

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you’ve been on the Internet.

Analytical/performance cookies. They allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties such as Hubspot and Google so we can better understand the usage of our website.

Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.

How to reject cookies?

If you want to reject any of the cookies that we use, then you will need to change your website browser settings.

Security

Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

Your rights

You have the following rights:

(a) the right to ask us to provide you with copies of personal information that we hold about you at any time;

(b) the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and

(c) the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.

If you wish to exercise any of the above rights, please contact us using the details specified above.

You can contact the credit reference agencies currently operating in the UK; the information they hold may not be the same, so it is worth contacting them all. They will charge you a small statutory fee.

(a) CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414

(b) Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk

(c) Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.

Third party sites

This website contains links to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect through this website and we cannot be responsible for personal information that third parties may collect, store and use through other websites. You should always read the privacy policy of each website you visit carefully.

The third party systems in the delivery of services via ASMX, such as email delivery, customer service applications and general email systems that we currently use are:

(i) Google Suite – We use the enterprise version of Gmail in order to provide our customers with the best available security when using email. We retain all customer emails.