Flow Traders

last update: 8 October 2026

Privacy Statement

This Privacy Statement from the Flow Traders group (“Flow Traders”), having its head office at Jacob Bontiusplaats 9, 1018 LL Amsterdam, the Netherlands, describes the manner in which Flow Traders collects, controls, processes, and transfers personal data. Please read this carefully.

For individuals in the United Kingdom, references in this Privacy Statement to applicable data-protection law include the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and any other applicable UK data-protection legislation. Where applicable, this Privacy Statement also explains the processing of personal data under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, as amended (“UK MLR”).

Personal Data We Collect

Flow Traders collects and processes personal data to carry out our business as a leading global technology-enabled liquidity provider. We only collect personal data on grounds permitted by applicable laws and regulations. Examples of personal data we may collect include:

Personal details (e.g., full name, nationality, gender, photograph, and IP address);
Identification details (e.g., passport or identification card, photo ID, national identification number, and social security number);
Contact information (e.g., phone number and postal address);
Information to comply with our regulatory obligations (e.g., know-your-counterparty information, due diligence checks, anti-money laundering checks);
Information relating to the prevention, detection and investigation of money laundering, terrorist financing and proliferation financing, including information obtained through customer due diligence, enhanced due diligence, sanctions screening, adverse-media screening and verification of beneficial ownership and control;
Records of your contact with us via phone calls, video calls, video conferences, and email, as well as video surveillance for the security of our buildings and systems;
Information collected through cookies and similar technologies on our websites and client portals; and
For visitors to our offices, information collected for visitor-management and security purposes, including your name, contact details, company, appointment details, identification information, entry and exit information, access-card information and images captured by CCTV.

How We Collect Your Personal Data

We collect personal data directly from you or from third-party sources, such as:

Regulatory authorities containing your personal data;
Public sources, such as newspapers and the internet;
Data files from other parties that have collected personal data about you, such as trade registers or businesses that contact us regarding our activities.
Credit-reference, identity-verification, sanctions-screening and anti-fraud providers;
Other Flow Traders group entities, financial institutions, prime brokers, professional advisers and service providers;
Competent authorities, law-enforcement authorities and other official sources where permitted or required by applicable law;
Visitor-management and access-control systems; and
CCTV cameras and other security systems operating at or around our offices.

Purpose of the Processing

Flow Traders processes personal data for various legitimate business and compliance purposes, including but not limited to:

Application process and organizational management – using data such as contact information, passport or ID, CV/resume, cover letter, position of interest, educational background, compensation, department, and job characteristics;
Personnel administration – using data such as name, contact information, date of birth, gender, employment contract type, nationality, expat status, and employment status;
Employee relations and talent management – using data such as employee ID, start date, department, performance ratings, and required licenses or certifications;
Technical support and employment management – providing limited access to your personal data to managers;
Governmental compliance – using tax information, social security information, and other legally required data;
Policy enforcement and legal claims – monitoring and enforcing Flow Traders’ policies, ensuring compliance with legal obligations, and establishing, exercising, or defending legal claims;
Statistical and analytical purposes;
Regulatory compliance Purposes- Flow Traders may also share your personal data with prime brokers for onboarding, account setup, and regulatory compliance purposes.

> In relation to counterparties, beneficial owners, directors, officers, > representatives and other persons whose personal data is provided to > us in connection with establishing or maintaining a business > relationship or entering into an occasional transaction, Flow Traders > may process personal data for the purposes of:

I. conducting counterparty due diligence and ongoing monitoring;

II. identifying and verifying customers, beneficial owners and persons acting on behalf of customers;

III. assessing and managing financial-crime, sanctions and fraud risks;

IV. preventing, detecting and investigating money laundering, terrorist financing and proliferation financing;

V. complying with obligations under the UK MLR and equivalent applicable legislation in other jurisdictions;

VI. making disclosures to competent authorities, law-enforcement authorities, regulators and other persons where required or permitted by law;

VII. maintaining records required by applicable anti-money laundering, counter-terrorist-financing, sanctions and financial-services legislation; and

VIII. deciding whether to establish, continue, restrict or terminate a business relationship or enter into an occasional transaction.

> Personal data received from a counterparty for the purposes described > above will not be processed for unrelated commercial or marketing > purposes unless a separate lawful basis exists and the processing is > permitted under applicable data-protection law.

Visitors- Flow Traders also processes visitors’ personal data for legitimate security and safety purposes, including to:

I. manage and verify access to our offices;

II. identify and authenticate visitors;

III. protect our employees, visitors, premises, systems and property;

IV. prevent and detect unauthorised access, theft, fraud, violence and other unlawful activity;

V. investigate security incidents and support internal investigations;

VI. assist competent authorities and law-enforcement authorities where required or permitted by law; and

VII. maintain records necessary for the security and operation of our offices.

Flow Traders will not process special categories of personal data unless (i) you have explicitly consented, (ii) processing is required by law, or (iii) processing is otherwise permitted under applicable law Where permitted by applicable law, certain processing activities, such as CCTV and security monitoring, may be carried out on the basis of Flow Traders’ legitimate interests, provided that those interests are not overridden by your rights and freedoms.

CCTV images are used for security, safety, prevention and detection of crime, incident investigation and the protection of people and property. CCTV is not used for unrelated commercial or marketing purposes.

Lawfulness of the Processing

We may process your personal data based on one or more of the following legal grounds:

Your consent;
Necessity for the performance of a contract or pre-contractual steps;
Compliance with legal obligations to which Flow Traders is subject;
Legitimate interests pursued by Flow Traders or third parties (if and in so far permitted under applicable law), such as performing business activities, AML/KYC purposes, preventing fraud, or conducting internal market research and protecting the security and safety of our offices, employees, visitors, systems and property.

Recipients of Personal Data

Your personal data may be stored in databases managed by the relevant Flow Traders departments. Your personal data may also be processed by the Compliance, Legal, Risk, Operations and Information Security departments, where required.

Flow Traders may engage third-party processors to process your personal data, as the case may be. Recipients or categories of recipients may include:

Flow Traders group entities;
prime brokers, banks, financial institutions and other counterparties;
identity-verification, sanctions-screening, fraud-prevention and technology providers;
professional advisers, auditors and insurers;
competent authorities, regulators, tax authorities and law-enforcement authorities; and
other persons where disclosure is required or permitted by applicable law.

Access to your personal data is strictly controlled through an extensive security system in our network. Access to our databases is limited to authorised personnel and will only be shared with other personnel, agents or service providers on a “need-to-know” basis and for the purposes set out above.

Transfers of Personal Data Outside the EEA

Candidates personal data is primarily stored in Flow Traders’ Human Resources Information System (“HRIS”), which serves as the main system of record for employee and applicant data. Departments or managers, including the Compliance department, may also store personal data for AML/KYC purposes, maintain additional records, such as manual files, spreadsheets, or access databases.

Some of your personal data may be transferred to, or stored in, countries outside the European Economic Area (“EEA”), including the United States of America, Singapore, and Hong Kong, in case is needed to develop the business purposes. The data protection laws in those countries may not provide the same level of protection as the laws in the EEA.

When transferring your personal data outside the EEA or Switzerland, Flow Traders ensures that appropriate safeguards are in place in compliance with the GDPR, including, where applicable:

Standard Contractual Clauses (SCCs) approved by the European Commission;
the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses;
binding Corporate Rules (BCRs) for intra-group transfers, where applicable;
an adequacy decision or UK adequacy regulation; and
other legally recognized mechanisms and technical, contractual, and organizational measures to protect personal data.

Flow Traders takes all reasonable steps to ensure that your data is protected and processed in accordance with this Privacy Statement and applicable data protection laws.

Retention Period

Personal data is retained as long as necessary for the purposes outlined and as required by law.

Your personal data may remain in our active databases for operational use, such as managing employment, payroll, or regulatory obligations. Once your data is no longer needed for these purposes, it will be archived or securely deleted in accordance with local laws and good business practices.

Personal data processed for AML/KYC, sanctions, fraud-prevention and regulatory-compliance purposes may be retained for the period required by applicable law, and for as long as reasonably necessary to establish, exercise or defend legal claims, manage regulatory enquiries or demonstrate compliance.

Job applicants: Personal data of candidates not selected will be retained for up to 3 years, subject to your consent. This allows us to consider you for future opportunities that may align with your profile. After this period, your data will be automatically deleted unless you provide renewed consent. We may retain some data for longer periods for statistical, historical, or legal compliance purposes, where permitted under applicable law.

Visitors: Visitor records are retained only for as long as reasonably necessary for visitor-management, security and safety purposes, unless a longer period is required to investigate an incident, establish, exercise or defend legal claims, comply with a legal obligation or respond to a regulatory or law-enforcement request.

CCTV: images are normally retained for a limited period and are securely deleted or overwritten when they are no longer required. Where CCTV images are relevant to a security incident, investigation, legal claim or regulatory or law-enforcement request, they may be retained for longer for as long as reasonably necessary for that purpose.

Your Data Subject Rights

Depending on applicable law, you may have rights to access, correct, delete, restrict processing, object, receive, or transmit your personal data, withdraw consent, and lodge a complaint with a supervisory authority.

Refusal to Provide Personal Data

Provision of personal data may be required by law or contract. Failure to provide certain data may prevent Flow Traders from entering into or executing a contract with you.

To exercise your rights or for any questions regarding your personal data, contact our Data Protection Team at [email protected]. Flow Traders will respond as soon as reasonably possible.