Last updated 24 May 2018
1. WHAT INFORMATION DO WE COLLECT?
[In Short: We collect some personal and business information voluntarily provide to us by you, as well as information relating to your demographics and interaction on our Sites]
Information Provided Voluntarily
[In Short: We collect personal information that you voluntarily provide to us when registering on the Sites, such as name, address, contact information, passwords and security data, payment information]
We collect personal information that you voluntarily provide to us when registering on the Sites, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as posting messages in our online forums or events) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. Your first and last name, email address, postal address, phone number, company details (if applicable) and other similar contact data.
Credentials. Passwords and similar security information used for authentication and account access.
Payment Data. Data necessary to process your payment if you make purchases of our products or services, such as your debit/credit card number, and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Business Information/Forex Metrics. Information relating to your foreign exchange involvement, such as the nature of involvement, currencies and exposure volumes, normal foreign exchange metrics/cycles, hedging strategies and challenges.
Other information.Information relevant to customer surveys and/or offers/site usage, preferences and interests.
All personal and/or business information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected
[In Short: We may collect information related to your online demographics (such as location, IP address and device/browser used) as well as information collected and stored using cookies and similar technologies to monitor your use of the Sites in order to tailor and improve your user experience.]
Some information is collected automatically when you visit our Sites. This relates to the following:
User Demographics We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Web beacons and tracking pixels are technologies used on web pages and emails to unobtrusively check that you have opened an email, clicked a web link or accessed some content on our Sites.
Overall, these technologies help us provide you with a better website experience, by enabling us to monitor which communications and pages you find useful and of interest and which you do not. These technologies in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website functionality.
Information Collected From Other Sources
[In Short: We may collect limited data from public databases, marketing partners, and other outside sources.]
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media and online profile information (e.g.LinkedIn, company websites, Facebook & Twitter accounts); marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
[In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.]
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a service contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive for the following:
To facilitate account creation and logon process with your Consent.
To contact you for market research purposes by email, phone, SMS or mail to gain more knowledge of your particular situation and how we can fulfill your needs.
To customize our Sites. We may tailor and our web pages communications, products, subscriptions and services offerings to suit your particular needs and improve the quality of your user experience.
To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences, which can include promotional emails about new products, special offers, events or other information which we think you may find interesting. You can opt-out of our marketing emails at any time (see the "What Are Your Privacy Rights? " below).
To send administrative information to you for Business Purposes. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To fulfill and manage your orders and subscriptions for Contractual reasons. We may use your information to fulfill and manage your orders, payments, debit orders and refunds made through the Sites.
Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
[In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.]
We only share and disclose your information in the following situations:
Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
With Your Consent. We may disclose your personal information for any other purpose with your consent.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
[In Short: We aim to protect your personal information through a system of organizational and technical security measures].
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
6. DO WE COLLECT INFORMATION FROM MINORS?
[In Short: We do not knowingly collect data from or market to children under 18 years of age].
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
7. WHAT ARE YOUR PRIVACY RIGHTS?
[In Short: You may review, change, or terminate your account at any time].
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/iustice/data-protection/bodies/authorities/index en.htm
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features, functionality or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites visit http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list - however, we will still need to send you service-related emails that are necessary for the administration and use of your account.
To otherwise opt-out, you may:
- Access your account settings and update your preferences.
- Contact us using the contact information provided
8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
[In Short: Yes. if you are a resident of California, you are granted specific rights regarding access to your personal information].
California Civil Code Section 1798.83, also known as the “Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems
9. DO WE MAKE UPDATES TO THIS POLICY?
[In Short: Yes. we will update this policy as necessary to stay compliant with relevant laws.]
10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- If you have questions or comments about this policy, you may email us at email@example.com.
- If you have any further questions or comments about us or our policies, email us at firstname.lastname@example.org.
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request via email to email@example.com. We will respond to your request within 30 days.
Phone: +1 (859) 202-9889