Privacy Policy
Introduction
This privacy policy explains how Griffin Markets Services Limited and other group companies
(“Griffin”) use your personal data when you visit our website www.griffinmarkets.com and when you
provide us with data through other means, as well as providing you with information on your privacy
rights.
When providing Griffin with information or visiting our site, we will process and store any personal
data in accordance with this Privacy Policy and the General Data Protection Regulation (GDPR).
Who we are
Griffin operates an OTC commodity trading platform. It has offices in London (86 Duke of York Square,
London SW3 4LY), in Paris (25 Rue Jean Giraudoux, 75116 Paris) and Milan (Regus, Piazzale Biancamano,
820121, Milan). You can contact us regarding this policy using the following contact details:
Website: www.griffinmarkets.com
Email: contact@griffinmarkets.com
Telephone (Switchboard): +44 (0) 20 7808 4240
Collection and use of information
You may choose to provide us with your personal data via email, phone or via our website. This
information is used for our internal purposes and enables us to provide and otherwise administer any
services you request. We may also use the information to help us enhance our services.
Your data may be shared with various stakeholders, both internal and external to Griffin, such as:
•Griffin’s authorized employees in the course of their duties;
•Griffin’s processors concerning the management of the website (website hosting company);
•legal and administrative authorities, in accordance with applicable laws.
Griffin does not collect sensitive personal data. Sensitive personal data includes racial or ethnic origin,
political opinions, religious or philosophical beliefs, data concerning health or a natural person’s sexual
orientation.
We may collect, use, store and transfer the following different kinds of personal data:
•identity data including first name, last name, username or similar identifier, title, date of birth,
gender and national insurance number or other national identifier;
•contact data including address, email address and telephone numbers;
•technical data including internet protocol (IP) address and login data;
•usage data including information about how you use our website and services.
You have the right to ask us not to process your personal data for marketing purposes. You may also
choose not to receive certain other communications from us by opting-out by phone, email or via direct
marketing emails sent to you.
Information Security
Griffin endeavours to record information accurately, keep it up to date, store and dispense personal
information securely, keep computer passwords secure and ensure that information being disclosed is
to an individual of the appropriate level and seniority.
Encryption shall be used to protect data during transfer over the internet or outside of the boundaries
of the Griffin infrastructure unless the transfer of confidential information without encryption is
authorised.
Your personal data will not be kept for longer than is necessary for the purpose(s). We store your data
for a period of time consistent with the following requirements:
• the achievement of the purposes for which the data was collected;
• any legal and regulatory retention period;
• the withdrawal of your consent, if applicable.
At the end of this period, your data will be deleted or anonymized in accordance with applicable laws
and regulations.
We have put in place appropriate security measures to prevent personal data from being lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data
to those employees, agents, contractors and other third parties who have a business need to know. They
will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.
Your rights and how to exercise them
You have rights defined in articles 12 to 21 of GDPR.
You have the right to request access to your personal information at any time (right of access).
You have the right to request the correction (right of rectification) or deletion (right to erasure) of your
personal data.
You have the right to request that your personal data be transferred to another organisation (right of
portability).
You have the right to ask to temporarily freeze the use of some of your data (right to restriction of
processing).
At any time, if you consider that your rights have not been respected, you may also file a complaint with
the French Data Protection Committee (Commission Nationale Informatique et Libertés, CNIL).
Disclosure of personal information
Griffin will not sell any of your personal information and will not share it for marketing purposes. Griffin
will not disclose information to third parties unless we are required to do so by law or if it is necessary
for the provision of services to you. We may pass information to third parties who provide outsourced
services to us. However, any such information will be shared only to the extent reasonably necessary for
supplier to perform services on our behalf and will subject to confidentiality obligations.
Data transfers outside the European Economic Area (EEA)
Your information may also be processed by staff who are based outside of the EEA for the purposes set
out in this Privacy Policy. Where we transfer personal information outside of the EEA, we will ensure
that adequate contractual safeguards are in place.
Use of cookies
A cookie is a small data file placed on the hard drive of your computer when you visit a website. A
“session cookie” expires when you end your session (i.e. close your browser). A “persistent cookie” stores
information on your hard drive so when you end your session and return to the same website at a later
date, the cookie information is still available. A “web beacon” is a small string of code that represents a
clear graphic image, a redirect URL or JavaScript and is used in conjunction with a cookie.
Griffin may collect information about you that is not personally identifiable. Griffin uses Google
Analytics and cookies to track website usage (using your IP address) and to assess patterns of usage to
assist us in developing our website and services. This may include information relating to the frequency
of your use of the website, the route by which you chose to access it and use of any hyperlinks available
on the website.
Changes to this policy
We reserve the right to update this policy from time to time. Any updates be published on our website.
This Privacy Policy was last updated on April 10, 2025.
