Privacy Policy

Last Updated: 5 December 2022

This Privacy Policy will explain how our organisation uses the personal information we collect from you.

1. Our contact details

Name: International Metal Platform AG ("IMP")

Registration No: CHE-176.883.315

Address: Zeltweg 16, CH-8610 Uster, Switzerland

2. The type of personal information we collect

Personal information means information relating to natural persons that allows the natural person to be directly or indirectly identified.

We currently collect and process the following information:

Personal identifiers, contacts and characteristics (for example, name and contact details)
Identification Number (for example, passport number, tax identification number), and
Background details (for example, language, date of birth, nationality, gender)
Job title and business relationships
Country of residence
Geographic location
Data on criminal proceedings
Online identifier (for example, IP addresses and cookie identifiers)

3. How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

because you register as a user on our platform
because you trade on our platform
because you provide a service to users of our platform
because you are an job applicant or employee of IMP or one of the service providers of IMP
because you complete a customer survey or provide feedback on any of our message boards or via e-mail

We also receive personal information indirectly, from the following sources in the following scenarios:

From public sources, such as public registries and databases, when we perform KYC processes
From private sources, such as private databases, when we perform KYC processes
From your employer, business partner, official agencies and authorities or other third parties

We also receive personal information, when you access our platform. Our server collects a set of user information, which is stored in the server’s log files. The information collected includes, but is not limited to, the IP Address, the date and time of access, the time zone difference relative to GMT, the name and URL of the downloaded file, the website from which the access takes place, the browser used and the operating system used.

The use of the general information does not involve identification of a specific person. The collection of this information or data is technically necessary in order to display our platform/website to you and to guarantee its stability and security. This information is also collected in order to improve the platform/website and to analyse its use. The legal basis for the temporary storage of the information and log files is our legitimate interest in being able to offer you our platform/website with maximum security and sufficient quality and to continuously improve it.

Our platform uses so-called cookies. Cookies are text files that are stored in or by the internet browser on the computer system or a mobile device oft the user. The cookie contains a characteristic string that allows the browser or mobile device to be identified unambiguously when the platform is visited again.

We only use technically necessary cookies on our platform/website, which are required for our platform/website to function. These cookies usually record important actions, such as the number of requests made, the editing of your privacy settings or when you fill out forms. Although you can block these cookies in your browser, some parts of our website may no longer function then.

The legal basis for the data processing when using technically necessary cookies is our legitimate interest, which lies primarily in ensuring the functionality and improvement of our website.

You can object to the use of cookies, for example, (i) by selecting the appropriate settings in your browser or (ii) by using appropriate cookie blocker software (e.g. ghostery, etc.).

For further information, visit allaboutcookies.org/

4. How we use the personal information

We use the information that you have given us in order to:

Provide the platform services to you (for example, processing your registration, processing your trades, managing your account)
Perform KYC, risk assessments and control
Email you with special offers on other products and services we think you might like

We may share this information with:

Providers to who we have outsourced certain services (for example, IT and hosting providers, payment service providers, banks, insurance companies, risk management and compliance providers and tools etc.)
Warehouses
Service providers, subcontractors and other business partners
Tax advisors, auditors, lawyers and other professional advisors of UMA
Counterparties
National and foreign authorities, agencies and courts.

5. Where your personal information is processed

The personal information may be processed within Switzerland, the European Union (the “EU”) or the European Economic Area (the “EEA”), but may also be processed in and transferred to a country outside of Switzerland, EU or EEA.

If we transfer data to a country without adequate legal data protection, we ensure an adequate level of protection as provided for by law using appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission) or we rely on the legal exceptions of consent, the performance of a contract, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal information or because it is necessary to protect the integrity of the data subjects.

6. What is the legal basis for processing your personal information

Under the EU General Data Protection Regulation (GDPR) and the Swiss Data Protection Act (SDPA), the lawful bases we rely on for processing this information are:

The processing of personal information is necessary for the performance of an agreement with or other obligations owed to you
You have given your consent to the processing of the personal information relating to you
The processing of personal information is necessary for the fulfilment of a legal obligation
The processing is necessary to protect the vital interests of the data subject or another natural person, or,
We have a legitimate interest in processing the personal information

7. How we deal with job applications

You can submit your application for a position with us by post or via the e-mail addresses provided on our website. Your application documents and all personal information thereby disclosed to us will be treated in the strictest confidence and will only be processed for the purpose of processing to your application for employment with us. Unless you have given consent which provides otherwise, your application file will either be returned to you after the conclusion of the application process or will be deleted / destroyed, unless it is subject to a statutory retention requirement. The legal basis for the processing your data is your consent, the performance of the contract with you and our legitimate interests.

8. How we store your personal information

Your information is securely stored at the AWS data centre London.

We keep the personal information for as long as it is necessary in accordance with the relevant purpose of processing or if there is another legal basis for doing so (e.g. statutory retention periods). We retain personal information that we hold on the basis of a contractual relationship with you for at least the duration of that contractual relationship and the limitation periods for potential claims or based on contractual retention obligations. Data that is kept solely for statutory retention reasons is additionally encrypted and protected. As soon as your personal information is no longer required for the above-referenced purposes, it will be set inactive, deleted or anonymised as far as possible.

9. Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information. We may charge you a small fee for this service.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you.

Please contact us at the following address, if you wish to make a request.

Name: International Metal Platform AG ("IMP")

Registration No: CHE-176.883.315

Address: Zeltweg 16, CH-8610 Uster, Switzerland

E-mail: info@imetalplatform.com

10. Changes to our privacy policy

We keep our privacy policy under regular review and place any updates on the webpage or, alternatively, communicate the update through the platform or via e-mail.

11. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

Name: International Metal Platform AG ("IMP")

Registration No: CHE-176.883.315

Address: Zeltweg 16, CH-8610 Uster, Switzerland

E-mail: info@imetalplatform.com

Alternatively, you can complain to:

Switzerland

Federal Data Protection and information Commissioner

Feldeggweg 1

CH-3003 Bern

Switzerland

+41 58 462 43 95

United Kingdom

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

European Union

Please file with the respective competent authority as per the following homepage: https://edpb.europa.eu/about-edpb/about-edpb/members_en