Scope of this Policy
The Service is operated by FXCintel Limited a company incorporated under the laws of England and Wales (registered No. 05881052) whose registered address is at 92-93 Great Russell Street, London, WC1B 3PS (“FXC“, “us” or “we“).
This Policy sets out the principles that govern the collection, use, storage, disclosure and disposal in connection with the Service of personal data of Users and of other members of staff of subscribing organisations (collectively referred to as “you“) by FXC and its subsidiaries, parent companies and other affiliates and by our subcontractors, service providers, representatives and agents where they act for or on behalf of FXC (“FXC Related Parties” or “our Related Parties“).
The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we collect and process your personal data. The following is a brief summary of our privacy practices.
This Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymised data, aggregated data, or coded data which, in a given form, cannot effectively be used to extract your personal data) (“Anonymised and Aggregated Data“). We reserve the right to generate Anonymised and Aggregated Data extracted out of any databases containing your personal data and to make such use as we sees fit of any such Anonymised and Aggregated Data.
Who is responsible for processing your personal data?
We are responsible for the processing of your personal data insofar as we collect it as part of the Service, through registration forms, surveys, questionnaires or by tracking Users’ use of the Service. Insofar as personal data of Users or other members of staff of subscribing organisations is posted to the Service by the organisation or its Users, that organisation may have the ultimate responsibility for the use of that personal data and we will handle it in accordance with the instructions of that organisation.
If you have any questions, a request or wish to make any complaint in relation to our use of your data, please contact us through the email address provided at the end of this Policy. The postal address and other contact details of FXC are available on the Service. Enquiries relating to our use of your personal data should be made for the attention of [indicate relevant officer/department, e.g., legal department].
What information do we collect about you?
The Service may collect and use both personal data and information about your use of the Service that is not identifiable to you personally:
- Personal data that you or your organisation may give to us or to our Related Parties in connection with your organisation’s subscription for the Service, for the purpose of signing-up to the Service or accessing the Service. This may include your name, the name of your organisation, your organisation’s address, telephone, email or other contact details, your date of birth, your role in the organisation, information relating to the equipment you use to access the Service (such as MAC numbers and IP addresses), and to the location of that equipment.
- Non-personal data including technical information such as the type of Internet browser you use, the date and time you access the Service, your Internet protocol address, and which pages you view on the Service.
- Information collected as part of the services we deliver such as information about your use of the Service.
- In addition, Users may post information to the Service which may include personal data, such as the names and roles of people within the subscriber’s organisation.
The purposes for which we collect your personal data
We collect your personal data for the following purposes:
- To meet our obligations to the organisation which subscribed to the Service, to deliver access to the Service to Users, to support Users’ and subscribers’ use of the Service, to enable us to handle enquiries and complaints.
- Insofar as permitted under applicable law, 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 the Service, to test, monitor, improve and upgrade the Service.
- 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 FXC’s internal business purposes such as keeping records of our communications with Users and subscribers to the Service, compiling statistical data concerning the use of the Service and performing analytics relating to the use of the Service by subscribers and Users.
When do we disclose your personal data to third parties?
We share your personal data with our Related Parties that provide services to us. This includes for example:
- subcontractors or service suppliers that we use to assist us in delivering the Service (including administration services, technical services relating to the maintenance, servicing and upgrading of the Service 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 the Service; and
- 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.
We ensures that such Related Parties do not use your personal data for any other purposes, that they do not disclose it to any other third parties and that they do not retain copies of your personal data except as necessary to provide services to us or to our customers or as may be required by law.
Our affiliates may have access to your personal data for the purpose of performing analytical studies and research. We will not disclose the results of such analysis or research to third parties or publish it except in the form of Anonymised and Aggregated Data.
We also reserve the right to disclose and transfer your personal data to other entities in connection with the sale or transfer of our business or those business activities relating to the Service or other products or services provided to your organisation (including, where necessary, in negotiations towards such sale or transfer). We will ensure that such acquirer will continue to process the personal data in accordance with this Policy (as it may be updated from time to time).
Other circumstances in which your personal data may be used or disclosed include the following:
- if we believe that such disclosure is reasonably necessary to enforce or apply the terms and conditions of a contract with a subscriber organisation or to protect our rights, property, the safety or integrity of our services, software or products, or otherwise as provided by law or required by any court of competent jurisdiction or any regulatory authority acting under statutory powers.
- where necessary to satisfy a legitimate request or order of a government body, public authority, regulator or enforcement agency, in response to a third-party subpoena (if on legal advice such response is required); or if necessary to defend us or our subscribers (for example, in a lawsuit).
We will fully co-operate with regulators, law enforcement agencies and other authorities to identify anyone who uses our products, service or software for illegal activities. We reserve the right to report to regulators and law enforcement agencies any activities that are believed to be unlawful.
How do we protect your personal data?
FXC uses appropriate technical and organisational measures to protect your personal data including:
- security measures including encryption, firewalls and physical security for our servers and information centres;
- limiting and controlling access to records of personal data to members of staff and Related Parties that require such access to perform their duties and services, through passwords, variable log-in rights and other technical and organisational access controls;
- ensuring confidentiality obligations are put in place when dealing with our Related Parties and other third parties;
- avoiding the collection or storage of personal data when it is unnecessary or for longer than reasonably needed or legally permitted or required and deleting it (or anonymising it) once we no longer need it or are no longer required to keep it as personal data; and
- seeking to keep your personal data up-to-date and correct.
However, we cannot guarantee that such protection will always successfully prevent attempts to gain unauthorised access, corruption or loss of personal data. Please bear in mind that transmissions over the Internet are not completely secure, and any information you send to or from this Service may be accessible by others. More specifically, email sent to or from the Service may not be secure. As a result, Users and organisations should take particular care in deciding what information to send or post to the Service.
Any passwords, ID numbers, or other special access numbers you might use to access any part of this Service are your responsibility; take care to safeguard them.
Data on children
Persons under the age of 16 should not transfer personal data to us unless they have the consent of their parent(s) or guardian(s). We do not knowingly collect, nor do we want to receive, personal data about individuals who are under 16 years of age.
Special categories of data
We do not seek to collect, store or process as part of the Service nor do we wish to receive any personal data relating to individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data or data concerning a person’s sex life or sexual orientation.
Transfer of personal data across borders
Personal data you provide to us through the Service is provided to us in [indicate the country from where FXCintel will be principally controlled]. We may use servers and cloud services to store data in other territories and may transfer the data to other territories for the purpose of storage and data management. Our Related Parties may have access to your personal data in different countries including, without limitation, the UK, the EU and the USA. We ensure that when personal data is transferred across borders, we do so incompliance with the law including (in the case of data exported from the EU) by putting in place, as between us and the party receiving the data, contractual terms for the protection of the interests of data subjects in the form approved by the European Commission.
Retention of personal data
FXC keeps records of personal data collected through the Service for limited periods of time and only as may be reasonably necessary for the purposes for which the data is collected.
Links to Third Party Websites
Contacting us about privacy questions or concerns
If you have any questions about this Policy, or any queries, requests or complaints in regard to the use of your personal data, please contact us by sending an email to the following address (indicating “PRIVACY REQUEST” in the message line): firstname.lastname@example.org or by sending a letter to: FXCintel Ltd, 92-93 Great Russell Street, 2nd Floor, London, WC1B 3PS.
If you request changes to the information we have on file for you — this could be the case if you believe that some information we have about you is incorrect, or there is some information about you that has changed (for example, if you no longer use a former email address) — please email email@example.com with the headline “PRIVACY REQUEST” in the message line. You may also contact us through the address indicated above.
Insofar as we collect your personal data in the European Union, you have a legal right to require access to any such personal data we hold about you and to require its rectification if it is incomplete or inaccurate.
This Policy was last changed on 20 June 2017. If we make changes to the Policy, the new version will be posted on the Service. We may change, modify, add or remove portions of this Policy at any time, and any changes will become effective immediately upon being posted unless stated otherwise.