Privacy Policy

This notice explains how and why your personal data is processed by Aura Futures Group Limited (Aura), (also referred to as “we”, “our” and “us””) visit our website at www.aurafutures.com (the “Website”) or otherwise communicate or engage with us.

Aura is a “controller” in relation to our use of your personal data. This is a legal term – it means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws.

In this notice, when we talk about personal data, we mean any information that relates to an identifiable natural person – in this case, you.

The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.

You should read this notice so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances from time to time. If you have any questions about this notice, please contact london@aurafutures.com.

The personal data we process about you broadly falls into two main categories: (i) Website Information / Browsing and Device Usage Information: and (ii) Contact and Query Information (where you make enquiries through our website). Just because these categories are noted below, that does not necessarily mean that we will collect all such personal data about you. What we collect will depend on how you engage with us, and thus the purpose which we have your personal data for.

We collect your personal data from various sources. The table below sets out the different types of personal data that we collect and the sources we collect it from.

Please note that if you do not provide us with your Contact Information we may not be able to provide you with any information you request.

We use your personal data for a number of different purposes in connection with your use of the Website, your communication or other engagement with us and the management and administration of our business. We must always have a “lawful basis” (ie a reason, prescribed by law) for processing your personal data.

The Personal data purposes table below sets out the purposes for which we process the different categories of your personal data and the corresponding lawful basis for that processing. For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.

Please note that where our processing of your personal data is either:

• necessary for us to comply with a legal obligation; or
• necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it,

and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract or engagement with you.

We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it.  Anonymised data cannot be linked back to you.  We may use it to conduct research and analysis, including to produce statistical research and reports.  For example, to help us understand and improve the use of our Website.

We will use your personal data to communicate with you:

• in relation to any correspondence you enter into with us (including via telephone);
• to administer our relationship with you;
• to respond to any questions or complaints that you may have; and
• to invite you to take part in market research or request feedback on our products and services.

[From time to time and with your consent (if required), we will provide you with information about our products, services, promotions and/or offers which may be of interest to you. Such communications will be sent either by email, text, post or telephone.

If you do not wish to receive such communications, you can refuse to give your consent (where your consent is required) or opt-out at any time by either following the instructions within the communication or by contacting us using the details below.]

Like most websites, our Website uses cookies and web beacons, which we deploy with your consent (if required), principally to enhance your viewing experience.

What are cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

Two types of cookies may be used on the Website – “session cookies” and “persistent cookies”. Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).

The system may also use web beacons which are similar but not identical to cookies in the way they operate.

What do we use cookies for?

We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.

Certain information (which may be personal data) – including computer and connection information, browser type and version, operating system and platform details and the time of accessing the website – will be automatically collected thorugh our use of cookies. This information helps us to improve our site and to deliver a better and more personalized service. It helps us:

• [To estimate our audience size and usage patterns.
• To store information about your preferences, so we can customize our site according to your individual interests.
• To speed up your searches.
• To recognize you when you return to our site.
• We occasionally carry out market research and business development.  A third party might help us to do this and they may send a cookie or web beacon.]

The table below summarizes the different types of cookie we use on the Website, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).

Cookies used on the Website:

How can I control or delete cookies?

Not all cookies require consent to be placed on your device.  Essential cookies do not require consent.  Non-essential cookies do require consent.  This is governed by privacy law. Some cookies and similar technologies maintain personal data. Some do not. You can find out more about this type of technology through your internet browser.

You may refuse to accept cookies by changing the settings on your browser. Your browser will tell you in simple terms how to do this, usually through a ‘help’ section. If you are at all uncertain about how to do this, your browser manufacturer should be able to show you how. However, if you change the settings to refuse cookies, you may be unable to access certain parts of the Website. Unless you have adjusted your browser settings so that the browser refuses cookies, our system will issue cookies when you log on to our site.

For cookies where we require consent (whether that requirement comes from eprivacy law or data protection law) we ask for this consent by a consent capture mechanism included in the banner you see when you first visit our Website.  You are asked to take a positive action (such as click to “ACCEPT”, or through the continued use of our website) if you do wish to give your consent.

If you use different devices to view and access the Website (e.g. your computer, smartphone, tablet etc.), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

Sometimes we need to disclose your personal data to other people.

Aura Group:

We are part of a group of companies. Therefore, we will need to share your personal data with other companies in our group for our general business purposes and, in some cases, for authorisations/approvals with relevant decision makers, reporting and where systems and services are provided on a shared basis.

Access rights between members of our group are limited and granted only on a need to know basis, depending on job functions and roles.]

Outside the Aura Group

From time to time we may ask third parties to carry out certain business functions for us, such as IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will seek to ensure that they have appropriate security standards in place to protect your personal data. Examples of these third party service providers include  our [IT systems software and maintenance, back up, and server hosting providers].

In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right, including where:

• we buy, sell or transfer our business (or part of it) in connection with a share or asset sale or outsourcing, we may disclose or transfer your personal data to the prospective seller, buyer or transferor and their advisors; and
• we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers, investors or others.

We have set out below a list of the categories of recipients with whom we are likely to share your personal data:

• IT support, Website and data hosting providers and administrators;
• consultants and professional advisors including legal advisors and accountants;
• courts, court-appointed persons/entities, receivers and liquidators;
• business partners and joint ventures;
• insurers; and
• governmental departments, statutory and regulatory bodies (including tax authorities).

We may transfer your personal data to internal or external recipients that are established in jurisdictions other than your own. [For example, we currently transfer some personal data we collect in the UK/Europe to our sales operations teams in the US in order for us to meet the needs outlined in any contracts and services committed in that jurisdiction].

Please be aware that the data protection laws in some jurisdictions may not provide the same level of protection to your personal data as is provided to it under the laws in your jurisdiction.

If you are based in Europe and we transfer your personal data outside the European Economic Area, we will only make that transfer if:

• that country ensures an adequate level of protection for your personal data;
• the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States;
• we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission;
• the transfer is permitted by applicable laws; or
• you explicitly consent to the transfer.

For more information regarding the transfers undertaken by us and the protections put in place, please contact us using the details set out at the end of this Notice.

We will take specific steps (as required by applicable data protection laws) to ensure we take appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.

We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing your personal data.  This will depend on a number of factors, including:

• any laws or regulations that we are required to follow;
• whether we are in a legal or other type of dispute with each other or any third party;
• the type of information that we hold about you;
• whether we are asked by you or a regulatory authority to keep your personal data for a valid reason; and
• the period of time during which any claims or proceedings can be brought against us or a member of the group to defend against any such claims.

For more information on our data retention practices, please contact [Insert appropriate email address].

Where our processing of your personal data is based on your consent (please see the table above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.

Where our processing of your personal data is based on the legitimate interests (please see the table above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.

[Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.]

You have the right to (subject to applicable laws and certain limitations):

• access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
• require us to correct any inaccuracies in your personal data without undue delay;
• require us to erase your personal data;
• require us to restrict processing of your personal data;
• receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (please see the tables above) and where the processing is automated; and
• object to a decision that we make which is based solely on automated processing of your personal data (however, we do not currently conduct any such decision making).

If you wish to exercise any of these rights please contact london@aurafutures.com in the first instance.

You may also have the right to lodge a complaint with the relevant data protection regulator (for example the Information Commissioner’s Office in the UK).

We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice. We also encourage you to check this notice on a regular basis.

If you want more information about any of the subjects covered in this Notice or if you would like to discuss any issues or concerns with us, you can contact london@aurafutures.com.