All Options processes personal data in compliance with applicable European data protection laws, including the Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”). Please read this policy carefully.
Collection of personal data
All Options collects and processes personal data in order to carry out its business. All Options only collects personal data on grounds permitted by regulations and laws. Examples of personal data All Options may collect include:
- personal details (such as full name, nationality, gender, photograph and IP address);
- identification details (such as passport or identification card, photo ID, national identification number and social security number);
- contact information (such as phone number and postal address);
- information in order to comply with our regulatory obligations (such as know your counterparty information, due diligence checks and anti-money laundering checks);
- records of contact you have with All Options via phone calls and e-mail and video surveillance for the security of our buildings and systems; and
How does All Options collect personal data?
The personal data All Options collects and processes is directly provided by you or obtained from other third party sources. All Options may use personal data collected from third party sources, which may come from publicly available information, previous or current employers, third party referees, government agencies, pre-employment screening agencies or other organisations. If you elect to not give All Options your personal data, All Options may be unable to employ you, or procure services or otherwise engage with you.
Purpose and lawfulness of processing
The processing of personal data is being conducted for various legitimate business and compliance purposes, which are, but not limited to:
- Administration: if you engage with All Options, All Options may use your personal data. Such processing is legally permissible under Art. 6(1)(f) GDPR as necessary for the purposes of the legitimate interests pursued by All Options, which are managing the relationship, verifying your identity and sending relevant information.
- Counterparty: for the purpose of entering into and performing contracts with you or the business you are related to, All Options may request/require and process certain personal data. By way of example, you may be a contact person, shareholder, authorised signatory or ultimate beneficial owner of one of our counterparties. Such processing is legally permissible under Art. 6(1)(b) GDPR as necessary for the purposes of performance of a contract by All Options, which includes accepting counterparties, carrying out risk assessments, risk management, reporting and carrying out our business activity.
- Recruitment: when you apply for a job on this site, your personal data will be processed for the purposes of managing All Options’ recruitment related activities, which include setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereto, and as is otherwise needed in the recruitment and hiring processes. Such processing is legally permissible under Art. 6(1)(f) GDPR as necessary for the purposes of the legitimate interests pursued by All Options, which are the solicitation, evaluation, and selection of applicants for employment.
- Legal obligations: All Options may be required to process your personal data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. All Options may also use personal data to meet its internal and external audit requirements, information security purposes, and as All Options otherwise believes to be necessary or appropriate: (a) under applicable law (including the GDPR), which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce All Options’ contractual relationship with an individual; and (d) to protect All Options’ rights, privacy, safety, or property, or those of other persons. Such processing is legally permissible under article 6(1)(c) and article 6(1)(f) GDPR.
All Options will update this policy if the processing of personal data changes.
All Options will only process special categories of personal data as set out in article 9 GDPR or criminal records as set out in article 10 GDPR if you consent to the collection, the collection is reasonably necessary for All Options’ business activities, or in circumstances permitted by the GDPR.
Disclosure of personal data and the use of third party service providers (processors)
All Options only discloses personal data when necessary to conduct its business operations as described below. When All Options discloses personal data, it will do so in accordance with applicable data protection and security requirements.
Within All Options: the All Options business is supported by several All Options teams and functions, and personal data will be made available to them if necessary for the provision of services and HR administration for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal data.
Third-party suppliers: All Options is supported by service providers around the world. Personal data will be made available to these parties only when necessary to fulfill the services they provide to All Options, such as software, system, and platform support, recruitment services, clearing services, cloud hosting services, advertising, data analytics, and order fulfillment and delivery.
Third parties for legal reasons: All Options will share personal data when it is required, such as:
- compliance with legal obligations and to respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
- in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
- to protect All Options’ rights, users, systems, and capabilities.
Recruitment: When you apply for a job on this website, your personal data will be shared with Recruitee, a cloud services provider located in the Netherlands – having its servers in the EEA – and engaged by All Options to assist managing its recruitment and hiring process. Accordingly, if you are located outside of the EEA, your personal data will be transferred to the EEA once submitted via the All Options website.
Transfers to third countries and safeguards
Your personal data may be transferred to and processed outside the EEA (including Curacao and the United States of America) for the purpose as described in this policy. Your personal data may be located outside the country they were collected in, including to servers situated offshore. When All Options transfers personal data from the European Economic Area to other countries in which applicable laws do not offer the same level of protection to personal data, All Options will take measures to provide an appropriate level of protection to such personal data.
All Options will retain personal data in accordance with the retention periods set by relevant rules and regulations. When you apply to a job on this site, your personal data will be retained by All Options up to four weeks after completing the application process and in any event delete your personal data three (3) months after providing All Options with your personal data. All Options may retain your name and the function that you applied for a longer period of time in order to optimize its recruitment process.
The existence of each of data subject’s rights
Under applicable data protection laws you may have rights, which may include the right to view your personal data that All Options maintains, correct or delete inaccurate personal data, restrict the processing of your personal data, oppose against the processing of your personal data, receive your personal data and transmit your personal data to another controller, withdraw consent provided by you, and lodge a complaint with a supervisory authority.
Questions and complaints
Should an individual have a question or wish to make a complaint in relation to All Options’ processing of personal or sensitive data, or a request for access or correction, they may contact the All Options’ Legal Department at Herengracht 433, 1017BR Amsterdam, The Netherlands (telephone +31 20 795 7022). Where a complaint is received, the Legal department will consider the complaint and, within a reasonable time, will decide whether the complaint warrants further investigation. The complainant will be advised by All Options of the outcome of its investigations within a reasonable time. Alternatively, you may refer your complaint to the Dutch Data Protection Authority.