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Privacy Policy
1. Introduction
This Privacy Policy explains how Spread Co Limited (“Spread Co”, “we”, “us” or “our”) collects, uses, shares
and protects your personal information, and the rights you have in relation to that information.
Spread Co is registered as a Data Controller with the Information Commissioner’s Office (ICO) under
registration number Z9317258.
This Privacy Policy applies to clients, prospective clients, website visitors and other individuals whose
personal data we process.
If you are an employee, contractor, or a third-party service provider, your personal data will also be processed
in connection with your employment or contractual relationship.
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal
data from individuals under 18. If you believe a child has provided us with personal data, please contact us.
2. Data Protection Principles
Data protection laws require that personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for specified, explicit and legitimate purposes and not used in a way incompatible with
those purposes. - Adequate, relevant and limited to what is necessary for the purposes for which it is processed.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes for which it is processed.
- Kept securely.
3. How To Contact Us / Exercise Your Rights
If you have any questions regarding this Privacy Policy or wish to exercise your data protection rights, please
contact us:
- Email: dp@spreadco.com
- Telephone: +44 (0)1923 832 682
- Post: Spread Co Ltd, Data Privacy, 1st Floor North, Argyle House, Joel Street, Northwood Hills,
Middlesex HA6 1NW
This Privacy Policy will be kept under regular review to take into account new legal/regulatory obligations
and relevant technology, changes to our operations and practices, and to ensure that it remains appropriate
to the changing environment. If we make significant changes, we will provide a prominent notice or notify
you through other appropriate means
4. What Personal Information Do We Collect About You?
We may collect the following types of personal information:
- Identity details
- Account information
- Income and wealth information
- Other personal information
- Technical information
- Marketing and communications preferences
- Communications content and channel information
If you provide us with personal information about someone else (for example a joint applicant or an
authorised representative), you must have their permission to do so.
We may also collect personal information from third-parties such as identity verification providers, fraud
prevention agencies, credit reference agencies (where applicable), introducing brokers with whom we have
a mutual relationship, and public/regulatory sources where necessary to comply with legal or regulatory
requirements.
4.1 Identity Details
This may include your salutation/title, full name, date of birth, address history (current and previous, where
applicable), telephone number(s), email address, nationality, copies of identity documents, ID/passport
number, national/tax identification number, employment status and employment details.
4.2 Account Information
This may include your username, password, account balance, trading history, trading performance, and
preferences for certain products and services.
4.3 Income and Wealth Information
This may include your income, sources of funds, savings, investments, and financial statements.
4.4 Other Personal Information
We may request additional information from time to time, for example information relevant to assessing
financial vulnerability or support needs. We will only collect this information where it is necessary for
providing our products and services or meeting regulatory expectations. Where required by law, we will
obtain your explicit consent.
In some circumstances, information you provide about health, disability, or vulnerability may constitute
special category personal data. Where we process special category personal data, we will do so only where
a lawful basis applies and a relevant condition under data protection law is met (for example, explicit
consent where required).
If you choose not to provide the information, we need to fulfil your request for a specific product or service,
we may not be able to provide you with the requested product or service, this is our obligation under the
Duty requirements to act in good faith and avoid causing foreseeable harm to customers.
It is important that you keep us up to date/inform us as soon as possible if you experience a change in your
personal circumstances or have any issues or other difficulties that may affect your ability to trade financial
products, and we will do our best to accommodate any changes.
4.5 Technical Information
This may include your Internet Protocol (IP) address, browser type and version, operating system and
platform, information about pages you visit on our website, and similar technical data.
4.6 Marketing and Communications Preferences
This may include your marketing preferences, preferences for receiving news updates, and records of
correspondence with us.
4.7 Communications Content and Channel Information
This includes records of communications between you and us, including by telephone, email, live chat, SMS,
messaging applications such as WhatsApp, secure portal messages, and other electronic communication
channels. This may include the content of messages, message metadata such as date, time, sender,
recipient and delivery status, and any contact details used for those communications.
5. How We Use Your Personal Information
We only process your personal information where we have a lawful basis to do so. These include:
- Contract: where processing is necessary to perform a contract with you or to take steps at your
request before entering into a contract. - Legal obligation: where processing is necessary for compliance with a legal or regulatory obligation.
- Legitimate interests: where processing is necessary for our legitimate interests (for example,
improving services, ensuring security, preventing fraud, managing risk and providing effective
customer support). We ensure that we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your information. We do not use your information for activities where our interests are overridden by the impact on you (unless we have
your consent or are otherwise required or permitted to by law). - Consent: where you have provided consent (including explicit consent where required), for example
for certain marketing activities, certain cookies, or certain types of information.
5.1 Verify Your Identity and Establish and Manage Your Account
We process personal information to set up and manage your account and to verify your identity. This includes
using third-parties to carry out identity, fraud and (where applicable) credit checks on our behalf, and
requesting documents from you to confirm your identity.
This processing is necessary for compliance with our legal and regulatory obligations, including requirements
to verify your identity and prevent money laundering and other financial crime. It may also be necessary for
our legitimate interests in ensuring the security and integrity of our services.
5.2 Provide You With Products and Services, Or Information About Our Products and Services
We process your personal information to provide you with our products and services, to administer your
account, and to provide information about our products and services where you have subscribed to updates
or webinars.
This processing is necessary for the performance of a contract with you and to comply with our legal and
regulatory obligations
5.3 Communicate With You About Your Account, Application and Our Services
We may use your personal information to communicate with you about your account, application, use of our
platform, service queries, administrative matters, requests for information, account status updates,
reminders, support requests, and scheduling assistance.
We may communicate with you by telephone, email, SMS, secure portal message, messaging applications,
such as WhatsApp, or other communication channels you choose to use with us or otherwise agree we may
use to communicate with you.
We process your personal information in this way where it is necessary to take steps at your request before
entering into a contract with you, to perform our contract with you, to comply with our legal and regulatory
obligations, and/or where it is in our legitimate interests to provide effective client support and account
administration.
You may request that we stop using a particular communication channel at any time, and we will take your
preferences into account where feasible. However, please note that where it is possible for us to do so, this
may affect our ability to provide certain support, administrative or account-related services efficiently. We may still need to contact you using certain communication channels where this is necessary for account administration, security, contractual, or regulatory purposes.
5.4 Call Recording and Messaging
We record telephone calls and retain electronic communications (including messages sent via approved or
supported electronic channels) as part of our regulatory compliance and oversight arrangements.
This may include records of any communications that we have with you in relation to the services we provide
to you and our ongoing relationship with you, including communications by telephone, email, SMS,
messaging applications such as WhatsApp, secure portal messages, and other electronic communication
channels.
Where we use messaging applications or other electronic communication channels, communications may be
recorded, retained, monitored, and stored in our systems to enable us to maintain an accurate and auditable
record of our interactions with you, respond to queries, evidence instructions or requests, resolve disputes,
and comply with legal and regulatory obligations.
Lawful basis: this processing is necessary for compliance with our legal and regulatory obligations, and, where
applicable, for our legitimate interests in maintaining service quality, security, and appropriate record
keeping.
If you do not wish to communicate via certain channels, please contact us to discuss alternative options.
However, certain communications may still need to be recorded and retained where required for compliance
with our legal and regulatory obligations
5.5 Improve Our Products and Services
We may use personal information (including feedback/surveys and usage information) to improve our
products and services. This is in our legitimate interests to develop and enhance our services.
5.6 Profiling and Automated Decision-Making
We may use your personal information to form profiles about you and may use automated tools (for
example for identity, fraud, or credit checks) where applicable. We do this where it is necessary to comply
with our legal and regulatory obligations or where it is in our legitimate interests to better understand you
and provide appropriate products and services.
Where decisions are made solely by automated means and have legal or similarly significant effects on you,
you have rights in relation to those decisions. These include the right to request human intervention, to
express your point of view, and to contest the decision. We will ensure that appropriate safeguards are in
place where required.
5.7 Enquiries and Disputes
We may process personal information to investigate enquiries, complaints and disputes, and to establish,
exercise or defend legal claims. This is in our legitimate interests and/or necessary for legal claims and
compliance.
5.8 Data Analysis
Our web pages and emails may contain web beacons, pixel tags or other similar type of data analysis tools,
which allow us to analyse how users interact with our website and communications (for example whether
emails are opened) and to improve our services and communications.
Where these tools rely on cookies or similar technologies, we will apply our cookie consent settings and
controls in accordance with applicable law and only use such technologies where you have provided consent,
unless an exemption applies.
Where personal information is processed in connection with these activities, we rely on our legitimate
interests in analysing and improving our services and communications, provided that such processing is
proportionate and does not override your rights and freedoms.
Where information is fully anonymised and no longer relates to an identifiable individual, it will no longer
be considered personal data and data protection laws will no longer apply.
Please refer to our Cookies Policy for more information about how we collect data about your online activity.
5.9 Surveys and Feedback
We may, from time to time, invite you to participate in surveys or provide feedback as part of our customer
feedback process. Where such surveys relate to customer service and are not used for marketing purposes,
we rely on our legitimate interests in improving our products and services.
We may also invite you to participate in other surveys. Where such surveys involve marketing activities or
are sent via electronic communications in a way that constitutes direct marketing, we will comply with
applicable marketing laws, including the Privacy and Electronic Communications Regulations (PECR), and
obtain your consent where required.
5.10 Internal Business Purposes and Record Keeping
We may process your personal information for internal business purposes, including administration, audit,
governance and compliance activities.
This processing is carried out in our legitimate interest and, where applicable, to comply with our legal and
regulatory obligations. We maintain records relating to our business activities, including our relationship with you and the services we provide, in order to ensure appropriate oversight, risk management, and compliance
with applicable laws and regulations.
5.11 Corporate Restructuring
If we undergo a corporate restructuring or part or all of our business is acquired by a third-party, we may
disclose your personal information as part of due diligence and related activities.
This is in our legitimate interests in ensuring the restructuring or sale is informed
5.12 Security (Premises)
If you enter any of our premises your image may be recorded on CCTV for security reasons. We may also take
your details to keep a record of who has entered our premises including day & time, who you are visiting,
employer, contact details and vehicle registration number. If you have an accident at our premises, this may
include an account of your accident.
This is in our legitimate interests to maintain a safe and secure working environment.
5.13 Compliance With Applicable Laws and Regulations
We may process your personal information to comply with applicable laws and regulations, court orders or
other judicial processes, or the requirements of any applicable regulatory authority. This is necessary to
comply with our legal obligations.
5.14 Marketing
We may use your personal information to send you marketing communications by email, telephone, SMS,
messaging applications such as WhatsApp, social media campaigns, or other agreed methods, where this is
permitted under applicable law, to inform you about our products and services.
We rely on our legitimate interests to send marketing communications where this is permitted under
applicable law and in accordance with the Privacy and Electronic Communications Regulations (PECR). Where
consent is required, including where required for marketing by electronic communication channels, we will
obtain your clear and specific opt-in consent before sending marketing communications.
You can opt out of marketing communications at any time by clicking the “unsubscribe” link in our marketing
emails, following opt-out instructions in other communications, or by contacting us using the details set out
in this Privacy Policy, also our Client Services at cs@spreadco.com.
Please note that opting out of marketing will not affect service-related communications. Service, account
administration and support communications do not require consent where they are necessary for the
performance of a contract or to comply with legal or regulatory obligations.
If you opt out of receiving marketing communications, we may retain your contact details on a suppression
list for as long as necessary to ensure we comply with your request not to receive further marketing
communications.
We do not share your personal information with third parties for their own marketing purposes unless you
have provided your explicit opt‑in consent. Where we use third‑party service providers to support our
marketing activities, they will process personal information only on our instructions and subject to
appropriate confidentiality and data protection obligations.
We will not use messaging applications such as WhatsApp to send you marketing communications unless this
is permitted under applicable law and, where required, you have provided specific consent to receive
marketing communications through that channel.
6. How We Obtain Your Consent
Where our use of your personal information requires your consent, we will obtain it in accordance with
applicable data protection laws. This means your consent will be freely given, specific, informed and
unambiguous, and obtained through clear affirmative action where required (for example, by selecting an
opt-in option).
We may obtain your consent through our website, application forms, account opening process, or through
our communications with you. Where we rely on your consent as the legal basis for processing your personal
information, you have the right to withdraw your consent at any time. You can do this by following the
relevant opt-out instructions (where provided) or by contacting us using the details set out in this Privacy
Policy.
Withdrawal of consent will not affect the lawfulness of any processing carried out before you withdraw your
consent
7. Disclosure Of Personal Data and Transfer Outside Of The UK and/or European Economic Area (EEA)
In the standard operation of our business, we may disclose your personal information to:
• Our associated companies
• Successors in title to our business
• Professional advisors (including solicitors, auditors and accountants)
• Identity verification providers, fraud prevention agencies and credit reference agencies (where
applicable)
• Any organisation or person to whom you have given us instructions to disclose your information
• Regulatory authorities, governmental bodies, and law enforcement agencies
• Third-parties necessary to provide our products and services to you (including communication,
messaging, customer relationship management and technology providers).
• Introducing brokers with whom we have a mutual relationship
We require all third‑party service providers to respect the confidentiality of your personal information and
to process it in accordance with applicable data protection laws and regulations. Where such providers act
as processors, they will process personal data only on our instructions and subject to appropriate contractual
safeguards.
Where we use third-party communication platforms, messaging applications, client relationship
management systems or technology providers, those providers may process personal information on our
behalf or, in some cases, as independent controllers under their own privacy terms. This may include
providers of messaging applications such as WhatsApp and client relationship management systems.
Please note that third-parties such as credit reporting, identity and reference agencies may keep a record of
any searches carried out and may use/share those details to assist other companies in performing their
searches for the purposes of fraud prevention and credit risk assessment.
We may transfer personal information to countries outside the UK and/or EEA, including to our group
companies and service providers. Where we do so, we will ensure that appropriate safeguards are in place
where required. These may include adequacy regulations, standard contractual clauses, the UK International
Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses, binding corporate rules,
or another lawful transfer mechanism. Where required, we will implement additional safeguards to ensure
that your personal data is protected to a standard essentially equivalent to that provided under UK data
protection law. Were required, we will carry out and document an assessment of the risks associated with
international transfers and implement supplementary measures where necessary.
You may contact us using the details set out in this Privacy Policy if you would like further information about
international transfers or copies of relevant safeguards (where applicable).
Where a third-party processes your personal information as an independent data controller, their processing
will be governed by their own privacy notice and practices. We encourage you to review the privacy
information provided by such third-parties. While we take care when selecting third-parties we work with,
their processing of your personal information is not covered by this Privacy Policy.
8. Security and Storage Of Personal Information
We take the security and safeguarding of your personal information very seriously. We store personal
information in secure systems, including electronic databases, secure IT infrastructure, paper-based files, and
other records, and implement appropriate technical and organisational measures to protect it against
unauthorised or unlawful processing, misuse, loss, destruction, or damage.
These measures may include, for example, access controls, encryption, secure storage, monitoring, and staff
training. Access to personal information is restricted to authorised personnel on a need-to-know basis for
legitimate business purposes. All employees are required to respect the confidentiality of personal
information.
We maintain internal governance arrangements, including the appointment of a responsible individual for
data protection oversight, to ensure compliance with this Privacy Policy and applicable data protection laws
and regulations.
We will only retain your personal information for as long as is necessary for the purposes for which it was
collected. When we determine that personal information is no longer required for thos purposes, we will
either securely delete or anonymise it. Retention periods are determined based on legal, regulatory,
contractual and business requirements and may be extended where necessary for legal claims, dispute
resolution or regulatory investigations.
In particular:
• In accordance with applicable anti‑money laundering and counter‑terrorist financing laws, we retain
customer due diligence records, supporting evidence, and transactional records for a minimum
period of five years following the end of our relationship with you.
• Personal information contained in deeds may be retained for up to twelve years following the end of
the relevant relationship.
• Where personal information is contained within recorded communications, whether by telephone
and relevant electronic communications such as email, SMS, messaging application including
WhatsApp, secure portal messages and other communication channels , in person or otherwise, we
retain these records in accordance with applicable legal and regulatory requirements, which may
require retention for at least five years, and longer where required or permitted by law.
Where you have opted out of receiving marketing communications, we will retain your contact details on our
suppression list for as long as necessary to ensure we comply with your marketing preferences.
9. Cookies
We use cookies and similar technologies. Where required, we will provide clear information about what
cookies do and why, and obtain your consent before placing non‑essential cookies on your device. Cookies
that are strictly necessary to provide a service you request (for example, security or core site functionality)
may be used without consent. For more information, please see our Cookie Policy
10. Remarketing
We use third-party advertising and remarketing services, such as Google Ads, to display advertisements on
third-party websites (including Google) to individuals who have previously visited our website.
These services use cookies and similar technologies to collect information about your interactions with our
website in order to display relevant advertisements on other websites.
Third-party vendors, including Google, may use cookies to serve ads based on your past visits to our website.
Any data collected will be processed in accordance with our Privacy Policy and the relevant third-party’s
privacy notice.
We will only use remarketing or advertising cookies where you have provided your consent via our cookie
settings, unless an exemption applies under applicable law.
You can manage your cookie preferences, including withdrawing your consent, at any time via our cookie
settings. You may also control cookies through your browser settings.
11. Links To Third-Party Websites and Services
Our websites, apps, messages or other communications may include links to external third-party websites,
applications or services.
If you communicate with us through a third-party application or service, such as WhatsApp, that third-party
may process your personal information in accordance with its own privacy notice and terms. We encourage
you to review the privacy information provided by any third-party service you use.
12. Technology Improvements
Technology improvements and developments may result in changes to the way in which we collect and use
your personal information. This may include the introduction of new communication channels, messaging
tools, client relationship management systems, or other technologies used to support client service, account
administration, record keeping and compliance.
Where such changes occur, we will ensure that your personal information continues to be processed in
accordance with applicable data protection laws and for the purposes set out in this Privacy Policy
13. Your Rights
You have rights under data protection law in relation to your personal information. These rights depend on
the circumstances and may be subject to conditions or exemptions.
Please contact us using the contact details provided in this Privacy Policy to make a request in respect of your
rights. We will respond without undue delay and in any event within one calendar month of receiving your
request. If we need further information from you (for example, to verify identity), the time limit will begin
once we have received this. If your request is complex or you make a number of requests, we may extend
the time to respond by up to two further months and will inform you within the initial one‑month period.
Please note that exercising certain data protection rights may affect our ability to provide services to you
where processing of personal data is necessary for those services.
13.1 Right To Be Informed
You have a right to be informed as to how we use your personal information in a concise, transparent,
intelligible manner way. We do this through this Privacy Policy.
13.2 Right To Access Your Personal Information
You have the right to access the personal information which we hold about you, known as a ‘subject access
request’. We may need to request specific information from you to help us understand the nature of your
request, to confirm your identity and ensure that you have the right to access the information (or to exercise
any of your other rights). This is another appropriate security measure to ensure that personal information
is only disclosed to the person who has the right to receive it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the request in such circumstances. We will respond without
undue delay and in any event within one calendar month of receiving your request. If we need further
information from you (for example, to verify identity), the time limit will begin once we have received this. If
your request is complex, or you make a number of requests, we may extend the time to respond by up to
two further months and will inform you within the initial one‑month period.
13.3 Right To Rectification Of Your Personal Information
You have the right to correct the personal information we hold about you if it is inaccurate or requires
updating. You can do this any time by contacting us using the details included in this Privacy Policy. If we have
shared your personal information with others, we will notify them about any rectification where possible.
13.4 Right To Request Erasure
You have the right to request erasure of your personal information in certain circumstances, known as the
‘right to be forgotten’, such as where we no longer need it or you withdraw your consent or we have
processed your personal information unlawfully.
However, this is not always possible, as there could be a reason for us continuing to process it (for instance,
we may need to continue using your personal information to comply with our legal obligations); and such
request will be subject to any retention limits we are required to comply with in accordance with applicable
laws and regulations, and subject to the section 5 of this Privacy Policy. If we have shared your personal
information with others, we will let them know about the erasure where possible. If you ask us, where
possible and lawful to do so, we will also tell you who we have shared your personal information with so that
you can contact them directly.
The right to erasure does not apply where processing is necessary for one of the following reasons:
• to exercise the right of freedom of expression and information
• to comply with a legal obligation
• for the performance of a task carried out in the public interest or in the exercise of official
authority
• for archiving purposes in the public interest, scientific research historical research or statistical
purposes where erasure is likely to render impossible or seriously impair the achievement of that
processing for the establishment, exercise or defence of legal claims
13.5 Right To Objection
You have the right to object to receiving direct marketing from us at any time, by clicking the ‘unsubscribe’
link in our emails or by contacting us directly. We will process your request promptly.
You also have the right to object to the processing of your personal information altogether or to specific
types of processing. If you exercise your right to object, we will stop processing your personal information
unless:
• there are compelling legitimate grounds for us to continue to process, which override your
interests, rights and freedoms
• the processing is for the establishment, exercise or defence of legal claims
Please note that if you exercise your right to object, we will assess your request on a case-by-case basis.
Where your objection relates to processing that is necessary for providing our products or services, or for
compliance with legal or regulatory obligations, we may be unable to continue to provide those services.
In such circumstances, this may result in a restriction of services or, where necessary, the closure of your
account
13.6 Right Of Restriction
You have the right to restrict the processing of your personal information in the following circumstances:
• you contest the accuracy of your personal information and we are verifying its accuracy
• the information has been unlawfully processed and you oppose erasure, requesting restrictions
instead
• we no longer need the personal information but you need us to keep it in order to establish,
exercise or defend a legal claim
• you have objected to us processing your personal information and we are considering whether
our legitimate grounds override your request
Please note that where you request restriction of processing, we may be unable to continue providing certain
products or services, and this may result in a limitation or suspension of your account where the restriction
affects processing necessary to deliver those services.
13.7 Right To Transfer Data - Portability
You have the right to transfer your personal information to another party of your choice where you provided
it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using
automated means
13.8 Right Not To Be Subject To Automated Decision-Making
If we have made a decision about you based solely on an automated process (e.g. through automatic
profiling) that affects your ability to use the services or has another significant effect on you, you can ask to
not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for
entering into, or the performance of, a contract between you and us. Even where a decision is necessary for
entering into or performing a contract, you may contest the decision and require human intervention.
14. Complaint
Data‑related complaints
If you wish to raise a complaint about how we have handled your personal information, you may do so using
the contact details set out in section 3 of this Privacy Policy. We will acknowledge receipt of your complaint,
investigate it without undue delay, keep you informed of progress, and notify you of the outcome.
If you remain dissatisfied with our response, you have the right to raise your complaint with the Information
Commissioner’s Office (ICO). Details of how to do this are available on the ICO website
https://www.ico.org.uk/make-a-complaint or by calling the ICO helpline on 0303 123 111
Non‑Data‑Related Complaints
If your complaint relates to any other matter, such as the services we provide, the conduct of our staff, or
any aspect of your experience with us, this will be handled under our standard Complaints Procedure. Details
of how to raise a non‑data‑related complaint, including the relevant contact information and process, can be
found in our Complaints Policy, available on our website or can be provided on request.
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