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Legal Privacy notice

Privacy notice

Membership enquiries and website use. This notice explains how PM MTF Ltd processes personal data under Article 13 of the General Data Protection Regulation.

Last updated: [date]

Draft text for review by PM MTF Ltd and its counsel before publication. Items in [square brackets] must be completed or confirmed.

1. Who is responsible

PM MTF Ltd, 21 Kasou, 1086 Nicosia, Cyprus (company no. HE 452207), is the controller of the personal data collected through this website.

Privacy contact
[privacy email]
Data Protection Officer
[name and email, or delete if no DPO is appointed]

2. What we collect

Through the membership enquiry form: your name, job title, business email, telephone number (optional), Legal Entity Identifier (optional), firm name, firm country, participant type, client category, settlement and contract interest, indicative volume, your message, your two confirmations, whether you asked for launch updates, and a reference number generated for your enquiry.

When you visit the website: our hosting provider’s server logs record your IP address, the date and time, the page requested and your browser type.

In your browser only: when you confirm the professional-audience notice, we store one item in your browser’s local storage (key cm.audience.v1, containing the value “professional” and a timestamp) so that the notice is not shown again for [180] days. It contains no personal data, is not a cookie and is never sent to us. You can delete it at any time through your browser settings.

This website uses no cookies, analytics, advertising tags, social-media plug-ins, or externally hosted fonts or scripts.

3. Purposes and legal bases

  1. To answer your enquiry and send information about membership: our legitimate interest in responding to business enquiries and building the market (Article 6(1)(f) GDPR). Where you are yourself the prospective contracting party, this is a step taken at your request before a contract (Article 6(1)(b)).
  2. To keep a record of enquiries and correspondence and to establish or defend legal claims: legitimate interests (Article 6(1)(f)).
  3. To keep the website secure and running (server logs): our legitimate interest in IT security (Article 6(1)(f)).
  4. If you apply for membership, the identity, anti-money-laundering and regulatory checks we must carry out: legal obligation (Article 6(1)(c)). We will give you a separate notice at that stage.
  5. To send you updates about the launch of Compute Markets, if you ask for them by ticking the optional box in the enquiry form: your consent (Article 6(1)(a)), which you can withdraw at any time.

You can object at any time to processing based on our legitimate interests, and to the use of your data for direct marketing.

4. Recipients

Authorised staff of PM MTF Ltd; service providers acting on our instructions (website hosting: [provider, country]; form and email processing: [provider, country]); our professional advisers; and public authorities where the law requires. We will share your details with Compute Desk (The Compute Index, Inc., [country to be confirmed]) only if you ask us to, for example about COMPUTE Clear. We do not sell personal data.

5. Transfers outside the EEA

[We do not transfer your data outside the EEA.] OR [Where a provider is outside the EEA, we rely on a European Commission adequacy decision (for example, the EU–US Data Privacy Framework for certified US companies) or on the Commission’s Standard Contractual Clauses. Contact us for a copy.]

If you ask us to share your details with Compute Desk, the transfer safeguard is [to be confirmed].

6. Retention

  • Enquiries that do not lead to membership: deleted [24] months after our last contact.
  • Enquiries that lead to an application: kept with the membership file for as long as the law requires (for anti-money-laundering records, generally five years after the business relationship ends [counsel to confirm]).
  • Launch updates: until you withdraw your consent, or until the launch updates end [and no later than 24 months after your enquiry: to be confirmed].
  • Server logs: [14] days, unless needed to investigate a security incident.

7. Your rights

You can ask for access to, correction or erasure of your data, restriction of processing, and data portability where it applies. You can object to processing based on legitimate interests, and you can object at any time to the use of your data for direct marketing. Where we rely on your consent (launch updates), you can withdraw it at any time; this does not affect processing carried out before you withdrew it. Write to [privacy email].

8. Complaints

You can complain to a data-protection supervisory authority, in particular in the EU Member State where you live or work or where the alleged breach took place. In Cyprus this is the Commissioner for Personal Data Protection: [address: to be confirmed], www.dataprotection.gov.cy.

9. Do you have to give us your data?

No, it is voluntary. Fields marked as required are needed to answer your enquiry; without them we cannot respond.

10. Automated decisions

We do not make decisions based solely on automated processing, including profiling.

11. Changes

We will publish any changes to this notice on this page.