City Traders Imperium


Last Updated 22/12/2020


Thank you for looking at the website for City Traders Imperium Limited (CTI, we, us).  It is important that we make this Privacy Policy available to you and that you understand it.  If you have any questions, please do contact us via email on [email protected].  You can find the legislation online if you look for the General Data Protection Regulation ((EU) 2016/679) (GDPR).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We hope however that if any issue does arise, you will speak to us first. 

You can find all our contact details below and if you need more, please just email us.

We both do and will respect your privacy and protect your personal data and this Privacy Policy explains to you how we will do this, both when you visit our websites and and when you use our software applications. 

We will comply with data protection law and principles and so your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

What we will explain in this below is also how we will collect and process your data, including that which you give to us as well as that which we correct. Before going any further, please understand that if you are under 18, we will NOT have any contact with you.


Under the law, we will become a data controller once you visit our website and every time that you do.  In this role, we are responsible for deciding how we hold and use personal information about you.

This means that it’s important that you know who we are, and so we have set out below, very clearly. our full details are:

Full name of legal entity: City Traders Imperium Limited.
Email address: [email protected].
Postal address: 124 Kemp House, City Rd, EC1V 2NX, London, UK.


We are always reviewing our Privacy Policy to keep it up to date. You can help us too as it’s important that the personal data we hold about you is accurate and current. So, please let us know asap if your personal data changes during your relationship with us.  Just use the contact details set out above.  This is your duty to us. Please help us to help you.


We collect personal information about you from the following sources:

Direct interactions: This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to give us information about you by filling in forms on our website of other services sites (together with our sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use our sites, subscribe to any of our services, search for a service and when you report a problem with our services or any of our sites. If you contact us, we will keep a record of that correspondence.

Automated technologies or interactions: As you interact with our sites, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:

Technical Data: from the following parties:

    • Analytics providers such as Google based outside the EU;
    • Advertising networks; and
    • Search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

Identity and Contact Data from data brokers or aggregators; and

Identity and Contact Data from publicly available sources.


We may collect, use, store and transfer different kinds of personal data about you.  This includes, in the main, the following:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments from you, details of products and services you have purchased from us and details relating to any legal services we provide or propose to provide to you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  • Usage Data includes details of your use our websites or services or your visits to any of our sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

To explain the terms which we use, Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.  It can also mean children and we are very clear above that this website and our business is NOT for anyone under 18.  So, if you are, log out now!). Nor do we collect any information about criminal convictions and offences.


When you consent to provide us with your personal data, we will also ask you for your consent to share your personal data with third parties for the purposes we have set out in this policy. 

Who are those third parties?  They are External Third Parties, who are service providers acting as processors based overseas who provide IT and system administration services.

They are also third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.   There also that possibility turned on its head.  We might want to acquire other businesses or merge with them. If a change like this happens, then the new owners may use your personal data in the same way as set out in this privacy policy.

Rest assured though.  We require all third parties to respect the security of your personal data and to treat it in accordance with the law. This means that we don’t let our third-party service providers use your personal data for their own purposes.  They can only them to process your personal data for specified purposes and in accordance with our instructions.


We will only use your personal data when the law allows us to. This can be for a number of reasons but those which are most common are set out below.  But remember, this list is not exhaustive:

  • Where you have consented before the processing.
  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

It’s really important for you to understand that in general, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message.  And remember, you are in charge and so you have the right to withdraw consent to marketing at any time by contacting us – you’ve got our details right towards the start of this policy, so do use it.

To give you more information on the “why?”, “what’s our purpose?” of all this, have a look below at a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so, together with our legitimate interests are where appropriate.   We are allowed to process your personal data for more than one lawful ground, and for this, we will look at the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.


  • To register you as a new customer

Type of data:

  • Identity;
  • Contact.

Lawful basis for processing:

  • Your consent.


  • To process and deliver your order, including managing payments, collecting money owed to us and delivering our software application services to you.

Type of data:

  • Identity;
  • Contact;
  • Financial Transaction;
  • Marketing and Communications.

Lawful basis for processing:

  • Your consent;
  • Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).


  • To manage our relationship with you including notifying you of changes to any services.

Type of data:

  • Identity;
  • Contact;
  • Profile;
  • Transactions;
  • Marketing and Communications.

Lawful basis for processing:

  • Your consent;
  • Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services);
  • Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)


  • To administer and protect our business and our Sites and the services including troubleshooting, data analysis and system testing.

Type of data:

  • Identity;
  • Contact;
  • Technical.

Lawful basis for processing:

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).


  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:

  • Technical;
  • Usage.

Lawful basis for processing:

  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)


Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. So, let us do what we need to get your contracts performed and give us the details we need, now that you know how we keep them safe and what we need them for. And remember to tell us about the changes!


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).   We won’t bombard you but unless you ask us not to (see below for how you opt-out – it’s easy and you are in charge), we will send you marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. 


We just don’t do it.  You can be sure that when you give us your personal data, we keep it personal.  We will never share your personal data with any third party for marketing purposes.


Remember what we said?  You’re in charge?  You can ask us to stop sending you marketing messages at any time by contacting us at any time.


Lots of people don’t like cookies, while others love the world it can open up to them.  So, which are you?  You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies.   But remember that if you want to look at everything on our website you may find that you are restricted if you disable or refuse cookies.


We’ve told you about the why, and the purpose, for which we collect your personal data. And in addition to this, we can now tell you that we 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 this isn’t enough and you would like an explanation about how this processing for the new purpose is compatible with the original purpose, please contact us at [email protected]. If we need to use your personal data for an unrelated purpose, we’ll tell you and explain the legal basis of this.  And rest assured.  While we may process your personal data without your knowledge or consent but we will only do this in compliance with the above rules and where this is required or permitted by law.


It’s a global village but your personal data may not be transferred or stored outside the EEA or the country where you and your authorised users are located save that your personal data may be transferred to the United States of America.  This is allowed because the US has had an adequacy decision which has been made in accordance with GDPR Art.45.   We can give you more details on all of this if you need it.


We promise you that the information you give to us is stored on secure servers.   But you have your part to play too and if we have given you (or where you have chosen) a password that enables you to access certain parts of our Sites or platforms, you are responsible for keeping this password confidential. Please do not share a password with anyone.   At our end, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Added to that we have procedures to deal with any suspected personal data breach which include notifying you and any applicable regulator where the law says we must.

And the law requires us to do other things too. We will keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax, regulatory and insurance purposes,  We might anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


As we say, you are in charge and under certain circumstances, the law gives you the right to take certain actions.

This means that you have the right to do the following:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the data privacy manager in writing. Call us and we can make arrangements.


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). But, if your request is clearly unfounded, repetitive or excessive we can ask you to pay or refuse to comply with your request.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


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