About this Data Privacy Policy

This Data Privacy Policy applies when you visit Binary Capital’s internet site. It also applies where we are in contact with you in other ways whether in your capacity as an individual or as a shareholder, or other representative of a company or other organisation.

Who we are

We are Binary Capital Limited (“Binary Capital”, “we”, “our”, and “us”), a private limited company registered in England and Wales under number 06692644. Our Registered Office is: 43-45 Dorset Street, London, England, W1U 7NA. We are registered with the UK Data Commissioner’s Office (“ICO”) under registration number ZA465166. Binary Capital Limited is authorised and regulated by the Financial Conduct Authority. Firm Reference Number 507900.

Contacting us

We are not required to appoint a formal data protection officer under data protection laws. However, our Head of Compliance is responsible for data protection in Binary Capital. If you have any questions about our Data Privacy Policy or your data, or to exercise any of your rights as described in this Data Privacy Policy or under data protection laws, you can contact us:

By post: Head of Compliance, Binary Capital Limited, 43-45 Dorset Street, London, England, W1U 7NA

By telephone: +44(0)207 139 1490

By email: [email protected]

You have the right to make a complaint at any time with a supervisory authority, in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is ICO who can be contacted at https://ico.org.uk or telephone on 0303 123 1113.

Data Controller

A controller determines the purposes and means of processing personal data. For the purposes of this policy, Binary Capital is a data controller in respect of any personal information we hold about you.

How we obtain your personal data

We collect personal data through services that we provide and receive. Typically, it comes from the following sources:

  • Contractual agreements or other material provided during our relationship.
  • Correspondence received from you such as email, telephone conversations, facsimiles, letters, face-to-face discussions, text messages, contact through our website and other forms of communication. We may keep a record of all correspondence received.
  • Depending on our business relationship, we may use third party firms for credit reference and money laundering checks.

Personal data we collect

If you are a customer, we collect information to assist in the provision of services to you. This information may include:

  • Your full name including title, maiden name, marital status, date of birth and gender.
  • Contact details such as residential address, email and telephone numbers.
  • Financial information, including your bank account and details of investments held with us and elsewhere. We may also record details of financial transactions placed across your accounts, whether held with us or elsewhere.
  • Identifiers such as your national insurance number or equivalent in overseas jurisdictions, tax reference, driving licence number, passport number, internet protocol address and our own internal identifiers.
  • Data used to access our client portal such as username, password, online preferences, and usage information.
  • Information required to conduct ‘know your client’ checks such as details relating to your passport or other photographic identification, your credit history, current and previous addresses and source of funds.
  • Our services are not directed at individuals under 18, and we do not knowingly collect their data.
  • We do not collect sensitive (or special categories of) personal data. Sensitive personal data is defined by data protection laws to include personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health.

If you are a business associate, we collect information to monitor services we have contracted for, or to assess services that are available to us. This information may include:

  • Your full name including title; Your occupation and job title and Contact details for you at your place of business such as address, email and telephone number.

Please note, we do not request any special categories of personal data. Under the GDPR, special category data is more sensitive and therefore needs more protection. Categories include race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; sexual orientation. When requested, you are not required to provide personal information, however, in doing so, we may not be able to proceed with a business relationship. We also receive personal data from third parties who we work closely with and who are entitled to share that data, e.g. Financial Advisers, investment Platforms and Regulators, but only as permitted by applicable law.

Data we collect online

Each time you visit Binary Capital websites we automatically collect the following data: Technical data, including the Internet Protocol (IP) address used to connect your computer to the internet, your login data, browser type and version, time zone settings, browser plug-in types and versions, operating systems and platforms, etc.; and Data about your visit, including the full Uniform Resource Locators (URL) of the internet sites you came through to our websites and which pages you visited (including date and time); page response times; download errors; length of visits to certain pages; page interaction data; and methods used to browse away from the page, provided we can do so lawfully

Cookies (small text files)

Binary Capital websites use cookies to distinguish you from other users of our websites to help us improve our applications and services. We do not use cookies to store any personally identifying data from users except to identify a user who has chosen to log in to the site. We do not use cookies to track user activities beyond our web site. You can control and/or delete cookies as you wish – for details, see: aboutcookies.org. You can delete all cookies that are already on your computer, and you can set most browsers to prevent them from being placed. If you do this, however, you will have to manually adjust some preferences every time you visit a site, and some services and functionalities will not work.

Legal basis for processing personal data

Our legal basis for processing your personal data is to carry out our obligations arising from any contracts between you and us and to provide you with the data and services that you request from us. This is not overridden by your data protection interests or fundamental rights and freedoms. We also collect personal data from you via our Website where we have your consent to do so or where we need the personal data to perform a contract with you. We also have a legal obligation to collect personal data from you to fulfill our regulatory and legal obligations.

How we use your data

We collect and use information to provide services to you, or to receive services from you, in accordance with contractual obligations. We only use your information for our legitimate interests or, in certain circumstances, for those of a third party.

Our legitimate interests are:

  • To administer and operate customer account(s) and to provide advisory and investment management services
  • To provide information relevant to the services we provide.
  • To facilitate our business operations and to ensure compliance with any legal and regulatory requirements that we are subject to.

If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you, we will not be able to perform our obligations under the contract between us.

Binary Capital will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.

Data retention

We can retain your personal information for as long as required to provide services to you. After the termination of contracts, we may retain data for a period of six years to comply with legal and regulatory requirements. After the expiration of six years, your personal data will be deleted. If compelled to do so by statutory, regulatory or governmental bodies, we may retain your personal data for longer than six years

Your rights

Data protection laws provide you with the following rights:

  • The right to check if we hold personal information about you.
  • The right to see the information we hold about you.
  • The right to have inaccurate information rectified.
  • The right to be forgotten and to have certain information erased.
  • The right to restrict processing of your personal data.
  • The right to request that your personal information is transferred to a commonly used machine-readable format and provided to you or a third party.
  • The right to object to the use of your information, including the right to restrict marketing.
  • The right to restrict automated decision making and profiling.
  • The right to withdraw consent previously provided to us to handle your information.

To exercise any of these rights, please get in touch using the contact details at the bottom of this policy.  Please note, if you are a client, by executing some of these rights, we may not be able to continue providing services to you.   If you are not satisfied with how we have handled your information you have a right to complain to the Information Commissioner’s Office (ico.org.uk).

Other sites and social media

If you follow a link from our websites, applications or services to another site or service, this Privacy Data Notice will no longer apply. We are not responsible for the data handling practices of third-party sites or services, and we encourage you to read the Privacy Data Notices appearing on those sites or services.

Changes to our Data Privacy Policy

From time to time, we may change this Data Privacy Policy. The current version will always be available from us in hard copy or on our website. We will post a prominent notice on our website to notify you of any significant changes to the Data Privacy Policy or update you by other appropriate means.

Smiling man in suit with cityscape background.

John Ruskin

Chairman

John is an accomplished CEO with over 25 years of international leadership experience, having built and sold two self-funded businesses to large, listed companies, and run two major divisions of world-leading enterprises.

He co-founded, built, and sold Cube Financial Group (1997 – 2006), the world’s first independent brokerage agency, which grew to £120M revenues and >100 employees in UK and US. Acquired by Société Générale’s Fimat (Newedge). Further to this he led Newedge’s Futures, Options, Equities & Fixed Income business (2006 – 2013), maintaining stable trajectory throughout the financial crisis, and growing the business to €200M revenues and 550 salespeople in eight markets.

John then co-founded, grew and sold Coex Partners Group (2014 – 2018), growing to £11M revenues in three years with an international client base of hedge funds and asset managers in UK, France, and US. Acquired by TP ICAP.

After his exit from Coex Partners he headed Agency Execution for TP ICAP (2018 – 2022), one of four divisions of the world’s largest Interdealer Broker, leading organic and acquisitive growth to increase revenues from £30M to £320M in four years. John also directed integration and strategic refocus of Liquidnet into TP ICAP (2021 – 2022), as a key member of the leadership team that closed $600M acquisition of Liquidnet in 2021 embedding a new vision, strategy, and roadmap for the business to ensure sustainable growth.

John is hugely passionate about social mobility, having worked with schools, community centres, social enterprise clubs, and the Metropolitan Police on multiple initiatives, and mentored young people through BTEC and A levels. He is a family magistrate.