This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data.
The FXC Group is made up of different legal entities, including FXC Group Limited, FX Compared Limited, FXC (IP) Limited and FXCintel Limited. This privacy notice is issued on behalf of the FXC Group so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the FXC Group responsible for processing your data. FXCintel Limited is the controller and responsible for this website. Our data protection registration number is ZA316987
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our DPO’s contact details are:
Name: Dan Spiegel
Address: 92-93 Great Russell Street, 2nd Floor, London, WC1B 3PS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 17 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide service to you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You or your organisation may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you or your organisation provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data.
- To meet our obligations to organisations which have subscribed to our service, to deliver access to our services to users, to support users’ and subscribers’ use of our services and to enable us to handle enquiries and complaints.
- To communicate with users and subscribing organisations in relation to other products or services that we or our partners offer.
- To personalise users’ access to our service, to test, monitor, improve and upgrade our services.
- To meet our legal obligations and the regulatory requirements to which we are subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties.
- For our internal business purposes such as keeping records of our communications with users and subscribers, compiling statistical data concerning the use of our service and performing analytics relating to the use of our service by subscribers and users.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can change your marketing and advertising preferences by [SPECIFY].
We will get your express opt-in consent before we share your personal data with any company outside the FXC Group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for any other purpose.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you.
We may share your personal data with the parties set out below.
- Other members of the FXC Group.
- Subcontractors or service suppliers that we use to assist us in delivering services (including administration services, technical services relating to the maintenance, servicing and upgrading of hosting services, data migration services and analytical services, marketing and customer service, payment processing services, and other outsourced services).
- Service providers that help us to test, monitor, improve and develop our services.
- Service providers and affiliates who help us compile, aggregate and analyse personal data in order to produce anonymised and aggregated data that we use, sell and publish.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the FXC Group. This may involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all members of the FXC Group, whether based in the EEA or not, to comply with the principles of the GDPR.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the “Privacy Shield” which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request.
Under certain circumstances, you have rights under data protection laws to:
- Request access to any personal data we hold about you.
- Request that we correct any personal data we hold about you.
- Request that we delete any personal data we hold about you.
- Object to us processing your personal data.
- Request restrictions on our processing of your personal data.
- Request a transfer of your personal data to a third party data controller.
- Right to withdraw any consent given to our processing of your personal data.
If you wish to exercise any of the rights set out above, please contact our DPO.
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.