Usage Conditions

Privacy Policy

Stratum understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all the people we do business with and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information About Us

Stratum Capital Markets (UK) Limited (“Stratum” or “we”, “our” or “us”), a Private Limited Company registered in England under company number 16441210 with registered address at 81 Rivington Street, London, UK, EC2A 3AY.

What Does This Notice Cover?

This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
• The right to access the personal data we hold about you. Part 10 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
• The right to restrict (i.e. prevent) the processing of your personal data.
  The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, you can ask us for a copy of that personal data in a structured, commonly used and machine-readable format to re-use with another service or business at your discretion.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

What Personal Data Do You Collect and How?

We collect and use only as much personal data as we need for our business purposes. The types of personal data that we collect are:

• Name
• Job Title
• Residential addresses for the purposes of providing environmental data services
• Contact details, including business email addresses and telephone numbers
• Account login details for use on our systems, including your username and password
  Your personal data may be provided to us in one or more of the following circumstances:

When registering to use our services (we will ask for certain personal data fields to be completed on our website or request information by email)

• When entering into a contract with us
• When you, or your employer, provide services to us
• When you give your contact details to a us (in the form of a business card or via other medium)
• When you contact us in writing, by post, email or via our website

We may also obtain your personal information where it is available in the public domain, from lawful public sources.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we will always have a lawful basis for processing personal data either because

• Consent: Because you have consented to our use of your personal data (e.g. by subscribing to emails) or to respond to a request from you.
• Contract: It is necessary for our performance of a contract with you including client contracts for environmental data services, or to facilitate communications with you and your employer in the course of our business dealings with your organisation, or to take payment from you or make payment to you.
• Legitimate Interests: To check that our clients are genuine and to prevent fraud, or where necessary to check that you and/or your employer are appropriately qualified to receive our services.
• Legal obligation: The processing is necessary for us to comply with the law.
  With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our products and services You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the lawful basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Data

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We regularly review the personal data that we hold and dispose of personal data that we no longer need for these purposes.

How and Where Do You Store or Transfer My Personal Data?

We will store your personal data within the European Economic Area (the “EEA”). This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards. We do not transfer your personal data to outside the European Economic Area.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

Do You Share My Personal Data

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or we need to provide it to regulatory authorities or insurance or fraud prevention agencies for fraud prevention or detection purposes complying or to comply with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with third parties to supply services to us. If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

How Can I Access My Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

Data Protection Team
Stratum Capital Markets (UK) Limited,
81 Rivington Street,
London,
United Kingdom,
EC2A 3AY

Email: [email protected]

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

This Privacy Notice was last updated in May 2026.