With respect of the collection, holding, storage, use, and processing of your personal information:
- we will process the data lawfully, fairly and in a transparent way;
- obtain the data only for valid business purposes that we have clearly explained to you, and not use the data in any way that is incompatible with those purposes;
- the data we collect will be relevant to the purposes we have told you about and limited only to those purposes; and
- we will take reasonable steps to ensure that the data is accurate and kept up to date.
Subject to applicable legal or other requirements, we will keep the data only as long as necessary and we will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
We need your personal information in order to provide our services to you. You provide us with personal information in a variety of ways such as;
(1) in the subscription agreement and related documents;
(2) client agreements or other forms;
(3) in correspondence and conversations with Kluis Commodity Advisors]’s representatives; and
(4) through transactions with Kluis Commodity Advisors or its affiliates. Commodity Advisors] uses personal information to open and service your account.
Additionally, some information is gathered automatically during your use of this site, as described below in the section “Cookies, tracking technologies and analytics.”
The personal information you provide us includes your name, address, telephone number, social security number; account information; assets and/or income information, date of birth, gender, age, financial details about you, such as your salary and details of other income, details of your savings, and information about your employment status. Additionally, if relevant to the product or service we provide you, your existing borrowings and loans, your marital status; family, lifestyle or social circumstances (for example, the number of dependents you have or if you are a widow or widower, or information on beneficiaries), and tax information.
Some of the personal information mentioned above may come from third party sources such as third-party services, databases and vendors that gather and provide information for firms like Kluis Commodity Advisors] to conduct compliance and regulatory reviews related to their clients]. These third-party sources include credit reporting bureaus and the Department of the Treasury’s Office of Foreign Assets Control search tool.
We may disclose personal information about you to parties other than our affiliates only for the following reasons:
- Legal and routine business reasons: We may disclose personal information if required or permitted by law. We may share information with government agencies, and self-regulatory organizations that have jurisdiction over us, for example as part of regulatory examinations or inspections. We may disclose personal information to comply with court orders, or subpoenas. We may disclose personal information to credit bureaus and the Department of the Treasury when conducting credit history and OFAC searches. We may from time to time disclose personal information to our auditors, accountants, attorneys, brokers, and back-up data storage providers for legal and business reasons. We may disclose personal information in the event of a sale of our business, transfer of our assets, or bankruptcy.
- Legal Basis: Without certain information we cannot provide you with our products or services. If providing certain information is optional, it will be marked as such.
- Transfer: We may transfer your information outside of your home country, and outside the European Economic Area. To protect such information, we undertake suitable safeguards in connection with such international transfers.
- To manage your account(s): We may also disclose personal information to certain service providers we have engaged to help us accept, service, manage, and protect your account(s). Such service providers may include consultants, software vendors, temporary workers, and our third-party account administrators, among others. Such providers may transfer your information outside of your home country and outside the European Economic Area. We undertake suitable safeguards to protect your information in these instances, for example, by including language in contracts with service providers addressing the protection of personal information.
- With your authorization: We may disclose personal information to certain persons at your request and/or with your consent.
- Cookies, tracking technologies and analytics: Kluis Commodity Advisors uses some tracking technologies such as cookies and web beacons to record your preferences, track your use of the site, monitor traffic, and to support and improve the site.
- Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files that permit a website to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Web beacons collect anonymous individual and/or aggregate information.
- Automated decision making: In establishing and carrying out our business relationship with you, we generally do not use any automated decision making pursuant to the General Data Protection Regulation, (the “GDPR”).
- Retention Period: Unless stated otherwise, your personal information will be held based on the following criteria: (1) For as long as we have reasonable business needs, such as managing our relationship with you and our managing operations (2) For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or (3) Retention periods in line with legal and regulatory requirements or guidance.
- Right to Object: You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. To exercise this right, please contact us using the contact details set out below.
GDPR Data Subject Rights: Under the GDPR, in certain circumstances, a European Economic Area resident has certain individual rights with respect to the personal information that we hold about them. In particular, such persons may have the right to: request access to any data held about them; ask to have inaccurate data amended; prevent or restrict processing of data which is no longer required; request transfer of appropriate data to a third party where this is technically feasible, and in some instances request data held about them to be deleted, provided the data is not required by Kluis Commodity Advisors; to perform services for you; provide products to you; defend a legal claim or to comply with applicable laws or regulations. Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. To exercise any of these rights, please contact us using the contact details set out below.
Kluis Commodity Advisors does not track its website’s visitors over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals.
This website is not intended for children and we do not knowingly collect data relating to children.
We maintain physical, electronic and procedural safeguards to protect your personal information. Additionally, Kluis Commodity Advisors’ site utilizes various information security measures such as secured files and buildings, internet firewalls, an intrusion detection system, encrypted data transmission, and operating procedures to protect your personal information. We direct parties performing services for Kluis Commodity Advisors, including accountants, attorneys, auditors, brokers, consultants, temporary workers, and our administrators, to protect your personal information and to only use such information to provide the services we have contracted with them to perform. Although, Kluis Commodity Advisors takes these measures, attacks by hackers and other unpreventable circumstances may compromise the security of your personal information.