FXCC Privacy Policy
Table of Contents
1. INTRODUCTION
2. PRIVACY POLICY UPDATES
3. COLLECTION OF PERSONAL INFORMATION
4. USES MADE OF YOUR PERSONAL INFORMATION
5. DISCLOSURE OF YOUR INFORMATION
6. CONSENT TO PROCESS DATA
7. HOW LONG WE KEEP YOUR PERSONAL DATA
8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
9. NO FEE USUALLY REQUIRED
10. TIME LIMIT TO RESPOND
11. HOW WE PROTECT YOUR INFORMATION
12. OUR COOKIE POLICY
1. INTRODUCTION
Central Clearing Ltd (hereinafter the “Company” or “we” or “FXCC” or
“us”). This Privacy Policy explains the way FXCC collects uses and
manages personal information from its active clients and potential clients.
FXCC is committed to safeguarding your privacy.
By opening a trading account with FXCC the client gives consent to such
collection, processing, storage and use of personal information by FXCC
as explained below.
It is the Company’s policy to respect the confidentiality of information
and the privacy of individuals.
This Privacy Policy aims to give you information on how we collect and
processes your personal data, including any data you may provide through
our website when you sign up to our website.
It is important that you read this Privacy Policy together with any other
privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you so
that you are fully aware of how and why we are using your data. This Policy
supplements the other policies and is not intended to override them.
At FXCC we understand the importance of maintaining the confidentiality of
our Client’s personal information and are committed towards ensuring the
security of any information provided by our clients through this website.
2. PRIVACY POLICY UPDATES
FXCC’s
Privacy Policy Statement will be reviewed from time to time to take account
of new laws and technology, changes to our operations and practices and to
make sure it remains appropriate to the changing environment. Any
information we hold will be governed by the most current Privacy Policy
Statement. The revised Privacy Policy will be uploaded in the FXCC website.
In this respect, the clients hereby agree to accept posting of a revised
Privacy Policy electronically on the website as the actual notice of FXCC
to its clients. If any of the changes made are of material importance then
we will notify you by email or by means of a notice on the home page. Any
dispute over FXCC Privacy Policy is subject to this notice and the Client
Agreement. FXCC encourages its clients to periodically review this Privacy
Policy so that they are always aware of what information FXCC collects, how
it uses it and to whom it may disclose it, in accordance with the
provisions of this Policy.
3. COLLECTION OF PERSONAL INFORMATION
In order to provide financial products and services to our clients
efficiently and accurately, when you apply to register to use one or more
of our services we will ask you for personal information. FXCC holds the
right and the duty by virtue of the business activity performed, to check
the accuracy of the data held in the databases by occasionally asking you
for updated data provided or for a confirmation of the accuracy of the
aforementioned.
The type of personal information we may collect can include (but is not
limited to):
-
Customer’s full name.
-
Date of birth.
-
Place of birth.
-
Home and work addresses.
-
Home and work telephone numbers.
-
Mobile / Telephone Number.
-
Email address.
-
Passport number/or ID number.
-
Government issued photo ID with signature.
-
Information on employment status and income
-
Information about previous trading experience and risk tolerance.
-
Information on education and profession
-
Tax Domicile and Tax ID Number.
-
Financial Data includes [bank account and payment card details].
-
Transaction Data includes [details about payments to and from you].
-
Technical Data includes [internet protocol (IP) address, your login data,
browser type and version, time zone setting and location, browser plug-in
types and versions, operating system and platform and other technology on
the devices you use to access this website].
-
Profile Data includes [your username and password, purchases or orders
made by you, your interests, preferences, feedback and survey responses].
-
Usage Data includes [information about how you use our website, products
and services].
-
Marketing and Communications Data includes [your preferences in receiving
marketing from us and our third parties and your communication
preferences].
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does
not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you,
we treat the combined data as personal data which will be used in
accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data).
We may also gather certain information about your use of our services. This
may include information from which you and/or your company can be
identified such as the times you log on, your volume of use of the
services, the types of data, systems and reports you access, the locations
from which you log on, duration of sessions and other similar data. The
information collected may be also lawfully obtained from third parties,
such as public authorities, companies that have introduced you to FXCC,
card processing companies, as well as publicly available sources that we
are lawfully permitted to process.
Your electronic and/or telephone communication with us is recorded and it
is the sole property of FXCC and constitutes proof of communication between
us.
You have a choice to supply any or all of the personal information
required. However, missing information may result in our being unable to
open or maintain your account and /or to provide you with our services
4. USES MADE OF YOUR PERSONAL INFORMATION
We gather process and manage the information which allows us to perform our
contractual obligations with you and to be compliant with our legal
obligations.
Below are the purposes for which your personal information is processed:
1. Performance of a contract
We process your data so as to provide you with our services and products,
and to be able to complete our acceptance procedure in order to enter into
a contractual relationship with our clients. In order to complete our
client on-boarding we need to verify your identity, perform the customer
due diligence as per the regulatory obligations, and we need to use the
acquired details to effectively manage your trading account with FXCC.
2. Compliance with a legal obligation
A number of legal obligations are imposed by relevant laws to which we are
subject, as well as statutory requirements, e.g. anti-money laundering
laws, financial services laws, corporation laws, privacy laws and tax laws.
In addition, there are various supervisory authorities whose laws and
regulations apply to us, which impose necessary personal data processing
activities for credit card checks, payment processing, identity
verification and compliance with court orders.
3. For the purpose of safeguarding legitimate interests
FXCC processes personal data so as to safeguard the legitimate interests
pursued by us or by a third party, where the legitimate interest is when we
have a business or commercial reason to use your information. Nevertheless,
it must not go unfairly against you and what is best for you. Examples of
such processing activities include:
-
Initiating court proceedings and preparing our defense in litigation
procedures;
-
means and processes we undertake to provide for the Company’s IT and
system security, preventing potential crime, asset security, admittance
controls and anti-trespassing measures;
-
measures to manage business and for further developing products and
services;
-
risk management.
4. For internal business purposes and record keeping
It may be required to process your personal data for internal business
and record keeping purposes,
which is in our own legitimate interest and is required in order to comply
with our legal obligations. We will also keep records in order to ensure
that you comply with your contractual obligations pursuant to the agreement
governing our relationship with you.
5. For legal notifications
Occasionally, the law requires us to advise you of certain changes to
products and/or services or laws. We may need to inform you of the changes
related to our products and services, therefore we will be obliged to
process your personal information to send you the legal notifications. You
will continue to receive this information even if you opt not to receive
direct marketing information from us.
6. For Marketing Purposes
We may use your data for research and analysis purposes, and your trading
history in order to deliver any analysis, reports, campaigns that may
interest you to your registered email address. Please note that you always
have the right to change your option in case that you do not wish to
receive such communications any longer.
If you do not want us to use your personal information in this way, please
send an email to support@fxcc.com asking not to be contacted for any
marketing purposes. If you are an on-line subscriber, you may login to your
Trader Hub user profile
and amend your notification preferences at any time.
7. To assist us in improving our products and services
We may use the personal information provided by you to ensure the highest
standards when providing our products and services.
5. DISCLOSURE OF YOUR INFORMATION
The main purpose we use your personal information for is to enable us
understand your financial objectives and ensure that relevant services are
appropriate to your profile. Further, this information helps FXCC to
provide quality services. While we may send you marketing material
(including but not limited to SMS or email communication for you to view,
margin calls, or other information) from time to time that we think will be
useful to you, we are conscious of the need to respect your privacy. Unless
you are informed otherwise, the personal information we hold is used for
establishing and managing your account, reviewing your ongoing needs,
enhancing customer service and products and giving you ongoing information
or opportunities that we believe may be relevant to you.
FXCC will not disclose your personal information without your prior consent
however, depending on the product or service concerned and particular
restrictions on sensitive information, this means that personal information
may be disclosed to:
-
Service providers and specialist advisers to FXCC who have been
contracted to provide us with administrative, financial, insurance,
research or other services.
-
Introducing brokers or partners with whom we have a mutual relationship
(any of whom may be within or outside the European Economic Area)
-
Credit providers, courts, tribunals and regulatory authorities as agreed
or authorized by law
-
Credit reporting or reference agencies, third authentication service
providers, fraud prevention, anti-money laundering purposes, identification
or due diligence checks of the client
-
Anyone authorized by an individual, as specified by that individual or
the contract
-
To an Affiliate of the Company or any other company in the same group of
the Company.
In case such disclosure is required to be made by law or any regulatory
authority, it will be made in order for FXCC to comply with any legal
obligations, protect itself from potential fraud, and maintain service
provider agreements. In case such disclosure is required it will be made on
a ‘need-to-know’ basis, unless otherwise instructed by the regulatory
authority. Generally, we require that organizations not under FXCC who
handle or obtain personal information as service providers to FXCC
acknowledge the confidentiality of this information, undertake to respect
any individual's right to privacy and comply with the Data Protection
Principles and this policy.
In some circumstances, we may pass on information to third parties if we
are legally required to do so or if we are authorized under our contractual
and statutory obligations or if we have been provided your consent.
We may also disclose your personal information to third parties if we are
under a duty to disclose or share your personal data in order to comply
with any legal obligation, or in order to enforce or apply our Site Terms
and Conditions.
6. CONSENT TO PROCESS DATA
By submitting your information, you consent to the use by FXCC of that
information, as set out in this policy. By accessing and using this you are
acknowledging that you have read, understood and agree with this privacy
policy. We reserve the right to change our privacy policy from time to time
and will update this page accordingly. Please review our policy as often as
possible – your continued use of the Site will signify that you agree to
any such changes.
The Site may, from time to time, contain links to and from the websites of
our partner networks and affiliates. If you follow a link to any of these
websites, please note that these websites may have their own privacy
policies and that we do not accept any responsibility or liability for
these policies. Please check these policies before you submit any personal
data to these websites.
You can withdraw your consent at any time, however any processing of
personal data prior to the receipt of your revocation will not be affected.
7. HOW LONG WE KEEP YOUR PERSONAL DATA
FXCC will keep your personal data for as long we have a business
relationship with you.
8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
By legislation we are required to respond to any personal data requests
within 30 days, unless the type of request requires more time for
investigation and assessment. The rights that might be available to you in
relation to the personal information we hold about you are outlined below:
-
Receive access to your personal data. This enables you to receive a copy
of the personal data we hold about you.
-
Request rectification/correction of the personal data we hold about you.
This enables you to correct any incomplete or inaccurate data we hold about
you. We may request additional information and documentation required to
validate the need for the requested change of data.
-
Request erasure of your personal information. You can ask us to erase
your personal data, exercising your right “to be forgotten”, where there is
no good reason for us continuing to process it. This request to erase your
personal data will result in the closure of your account and termination of
the client relationship.
-
Request to ‘block’ or suppress the processing of your personal data in
certain circumstances, such as if you contest the accuracy of that personal
information or object to us processing it. It will not stop us from storing
your personal information. We will inform you before we decide not to agree
with any requested restriction. If we have disclosed your personal
information to others, we will inform about the restriction if possible. If
you ask us, if possible and lawful to do so, we will also tell you with
whom we have shared your personal information so that you can contact them
directly.
-
Have the right to object to your personal data being processed for
direct marketing purposes. This also includes profiling in as much as it is
related to direct marketing. If you object to processing for direct
marketing purposes, then we shall stop the processing of your personal data
for such purposes.
-
Object, at any time, to any decisions that we may take that are purely
based on automated processing (including profiling). Profiling involves the
use of technology that helps us make decisions automatically, based on your
personal data that we collect from you or from third parties.
9. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise
any of the other rights). However, we may charge a reasonable fee if your
request is clearly unfounded, repetitive or excessive. Alternatively, we
may refuse to comply with your request in these circumstances.
10. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally
it may take us longer than a month if your request is particularly complex
or you have made a number of requests. In this case, we will notify you and
keep you updated.
11. HOW WE PROTECT YOUR INFORMATION
We endeavor to ensure protection of the information submitted to us, both
during transmission and once we receive it. We maintain appropriate
administrative, technical and physical safeguards to protect Personal Data
against accidental or unlawful destruction, accidental loss, unauthorized
alteration, unauthorized disclosure or access, misuse, and any other
unlawful form of processing of the Personal Data in our possession. This
includes, for example, firewalls, password protection and other access and
authentication controls.
However, no method of transmission over the Internet, or method of
electronic storage, is 100% secure. We cannot ensure or warrant the
security of any information you transmit to us and you do so at your own
risk. We also cannot guarantee that such information may not be accessed,
disclosed, altered, or destroyed by breach of any of our physical,
technical, or managerial safeguards. If you believe your Personal Data has
been compromised, please contact us.
FXCC may store your information in its databases for reference in order to
answer queries or resolve problems, provide improved and new services and
to meet any legal data retention requirements. This means we may retain
your information after you stop using the Site or our services or otherwise
interacting with us.
12. OUR COOKIE POLICY
Cookies are small pieces of text stored on your computer to help us
determine the type of browser and settings you are using, where you have
been on the website, when you return to the website, where you came from,
and to ensure your information is secure. The purpose of this information
is to provide you with a more relevant and effective experience on the FXCC
site, including presenting web pages according to your needs or
preferences.
FXCC may also use independent external service providers to track the
traffic and usage on the website. Cookies are frequently used on many
websites on the internet and you can choose if and how a cookie will be
accepted by changing your preferences and options in your browser. You may
not be able to access some parts of www.fxcc.com if you choose to disable the
cookie acceptance in your browser, particularly the secure parts of the
website. We therefore recommend you enable cookie acceptance to benefit
from all the services on the website.
You have the right to decide whether to accept or reject cookies by setting
or amending your web browser controls to accept or refuse cookies. If you
choose to reject cookies, you may still use our website though your access
to some functionality and areas of our website may be restricted. As the
means by which you can refuse cookies through your web browser controls
vary from browser-to-browser, you should visit your browser’s help menu for
more information.
If you continue to use this website without changing the cookie settings of
your web browser then you are consenting to our cookie policy
To learn more about cookies and how to manage them via your browser/device
please visit www.aboutcookies.org
CONTACT INFORMATION
If you would like to contact us with any queries or comments concerning our
privacy policy, please feel free to contact us via e-mail, postal address,
phone and fax or use our chat facility to IM a customer service
representative.
REGISTERED ADDRESS
FXCC
Central Clearing Ltd.
Bonovo Road – Fomboni,
Island of Mohéli – Comoros Union
Tel: + 44 203 150 0832
Fax: +44 203 150 1475
E-mail: support@fxcc.net