Private Policy
Collection of Personal Data
 
Why do we collect information?
 
As part of providing services, or information about our services, to you, and to ensure we do this in a compliant way, under the authorisation of our regulator, we must collect some personal information from our clients, potential clients, visitors to our website and service providers or suppliers. This may include third parties carrying out credit or identity checks on our behalf. The credit search is not seen or used by lenders to assess your ability to obtain credit and is required to adhere to money laundering regulations.
 
When you apply to open an account, when you maintain an account with us, or request a service we will require you to provide us with information about you. We will need to use the information in certain ways – from basic needs like verifying your identity to more complex things like determining whether financial trading is appropriate for you and processing your requests and transactions.  We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority.
 
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way.
 
Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.
 
Information collected
 
We may collect the following types of information from actual or potential customers:
 

● your full name, address and contact information including but not limited to phone number and email address;
● date of birth and gender;
● professional and employment details;
● identification details such as passport or driver's licence details;
● national/tax identification number;
● proof of address such as utility bills and bank statements;
● information about your income and wealth including details about your assets and liabilities, account balances, tax and financial statements;
● financial information including bank;
● location data;
● trading experience;
● transaction history;
● other personal information we require to meet your needs and provide our services to you.

 
We obtain this information through your use of our services or other dealings with us including through any of our websites, apps, the account opening applications, demo sign up, webinar sign up, subscribing to news updates and from information provided in the course of ongoing customer communication.
 
This information is held by us on servers. In addition, when you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language used, software crash reports and type of browser used. This information is essential for the provision and quality of the services. We do not collect personal information about you while using the services without your knowledge.
 
We collect information about visitors to our premises. We may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number.
 
We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
 
Management of personal information
 
We always take appropriate technical and organisational measures to ensure that your information is secure to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure. Your personal information is generally stored in our computer database.  Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
 

● passwords are required to access the system and passwords are routinely checked;
● data ownership is clearly defined;
● employees have restricted access to certain sections of the system;
● the system automatically logs and reviews all unauthorised access attempts;
● unauthorised employees are barred from updating and editing personal information;
● all computers which contain personal information are secured both physically and electronically;
● data is encrypted during transmission over the network; and
● print reporting of data containing personal information is limited.

 
We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary.
 
How do we store personal information and for how long
 
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
 
However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering laws which require us to retain:
 

● a copy of the documents we used to comply with our customer due diligence obligations; and
● supporting evidence and records of transactions with you and your relationship with us, for a period of five years after our business relationship with you has ended.

 
Means of collecting and processing personal information
 
We generally collect personal information directly from you. For example, personal information will be collected through our application processes, forms and other interactions with you during providing our services, including when you visit our website, call us or send us correspondence. We will only use the personal information as set out in this Privacy Policy. We will not retain or have access to any debit/credit card information. We will not collect sensitive information about you without your consent unless an exemption in the regulations applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
 
If you do not provide us with the personal information we request, we may not be able to provide you with our products or services or meet your needs appropriately.
 
We may also collect personal information about you from a third party, or share information with a third party, such as identity verification services, regulators, your introducing broker, marketing agencies, online vendors and service providers, and from customer lists lawfully acquired from third parties. In addition, we may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy. Any personal information will only be disclosed to third parties in accordance with this Privacy Policy. We do not sell or rent your personal information.
 
Information use
 
We use the personal information we collect from you to deliver our services, to provide client support, to undertake necessary security and identify verification checks, to comply with relevant laws and regulations and other legal obligations, to process any of your online transactions, to assist your participation in third-party promotions, meet certain business requirements and for any other purpose related to the operation of the services. Your personal information may also be used by us to provide you with promotional offers and information regarding our products and services and in order for us to better provide a range of products and services and improved customer service. From time-to-time, we may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary, and, therefore, you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as postal code or age).
 
Certain excluded disclosures
 
We may disclose your personal information if required to do so by law, or if we believe in good faith that such action is necessary to:
 
(1) comply with any legal process served on us or in circumstances where we are under a substantially similar legal or regulatory obligation;
 
(2) protect and defend our rights or property; or
 
(3) act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, our Affiliates, or any other user of the Services in any way including, but not limited to, price manipulation or payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).
 
We reserve the right to share this information (together with your identity) with other financial CFD providers, banks, credit card companies, and appropriate regulatory and legal agencies.
 
Transfer of personal data abroad
 
We may need to transfer your information to other group companies or service providers in countries in or outside the EEA (European Economic Area). This may happen if our servers or suppliers and service providers are located elsewhere. When we transfer your personal data outside the EEA, we endeavour to protect your privacy and rights by ensuring the recipient has adequate systems and measures to safeguard data and by agreeing to EU approved model contractual clauses with the data recipient which are designed to protect you.
 
By using or participating in any service and/or providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the EEA.
 
Your rights relating to your Personal Data
 

● You have the right to be informed
● You have the right to check what personal information is held by us
● You have the right to Rectify your data
● You have the right to Remove your data (Erasure)
● You have the right to “Opt out”
● You have the right to object to processing of your Personal Data
● You have the right to request the restriction of processing of your Personal Data
● You have the right to request the transfer of your Personal Data
● You have the right to withdraw consent

 
 
Cookies
 
1. What is a Cookie?
 
Cookies are data, stored in small text files on your computer as you browse the web. In and of themselves, cookies are harmless bits of text that are locally stored and can easily be viewed and deleted. Cookies allows the website to “remember” your actions or preferences over a period of time.
 
2. Types of Cookies
 
Cookies can be classified by their lifespan and the website to which cookies belong. Lifespan of cookies are either:
 

● Session cookies that are temporary and deleted once the user closes their web browsers;
● Persistent cookies may stay on your computer for a long time after the session is ended. Website cookies are either;
● First party cookies that belong to the website you are browsing, e.g. cookies used to identify you when you login;
● Third party cookies belong to a different website to the website you are visiting, e.g. advertising tracking cookies.

 
3. Cookies on our Website
 
We use cookies to assist us in securing your trading activities and to enhance the performance of our website. Cookies used by us do not contain any personal information nor do they contain account or password information. They merely allow the site to recognize that a page request comes from someone who has already logged on.
 
We use the following types of cookies:
 
Essential/Strictly Necessary
 
Essential/Strictly Necessary cookies help make a website usable by enabling basic functions like page navigation, request for services and access to secure areas of the website. The website cannot function properly without these cookies. These cookies do not store any personally identifiable information.
 
The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission.
 
Performance/Analytics Cookies
 
Performance/analytics cookies collect information about how you use the website, which pages you visit and if you have errors. These cookies allow us to count visits and traffic sources,so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. These cookies do not store any personally identifiable information.
 
Functional Cookies
 
Functional cookies enable a website to remember and record information about choices that you have made, and they also allow us to tailor the website to suit your needs. These cookies do not store any personally identifiable information.
 
Targeting Cookies
 
These cookies may be set through our site by our advertising partners, e.g. DoubleClick by Google. They may be used to build a profile of your interests and show you relevant adverts on other sites.
 
If you do not allow these cookies, you will still see the same number of advertisements, however they may be less relevant to you. These cookies will be on by default but can be managed directly by visiting Google's Ads Personalisation and/or Your Online Choices.
 
We may share Web site usage information about visitors to the website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pages you have visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable.
 
Third cookies
 

● Measure the effectiveness of our advertising initiatives;
● Provide information to our partners about your visit to their website;
● Gather information that may be used to advertise to you on other third-party websites;
● Send targeted advertisements to you on third party websites;

 
We do not guarantee that the lists of third party cookies set out above are up-to-date, but we will use our reasonable endeavours to update our cookies policy if any changes occur.
 
Your Choices
 
If you wish to block cookies, you may do so through your browser’s settings. You can delete cookies that are already on your computer and you can set your browser to prevent them from being placed going forward. Please refer to the browser's help menu for further information. However, please bear in mind that disabling cookies may adversely affect your user experience on the Service.
 
For more information on how to manage your cookie settings in respect of third party cookies please go to www.allaboutcookies.org. If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to http://www.youronlinechoices.com.