In this Privacy Policy we describe how FXTM (“we” or “us”) collects and processes the personal data of its existing and prospective clients. FXTM is comprised of different legal entities, details of which can be found in Section 2 below. Each company of FXTM controls the personal data of its own clients and is responsible for ensuring that such is used fairly and lawfully. This Privacy Policy is issued for and on behalf of FXTM and each company thereof.
This Privacy Policy is addressed to legal and or physical persons who provide their personal data to FXTM and/or visit and/or use FXTM websites, trading platforms, software application, social media and/or any other electronic services (“Electronic Services”).
At FXTM, we acknowledge that confidentiality and security of your personal data is of utmost importance to you hence we have developed specific policies and practices designed to protect your personal data. Protection of your personal data requires, among others, the establishment by FXTM of appropriate technical and organisational measures as a means to ensure a high level of data protection.
Additionally, FXTM will monitor, audit and document internal compliance with data protection policies and applicable statutory data protection requirements, including local data protection legislation. We are constantly working towards enhancing data protection practices within FXTM such as assignment of responsibilities, raising awareness and training the staff involved in data processing operations.
This Privacy Policy is based on the privacy and data protection principles applicable to the countries in which we operate. This Privacy Policy will be reviewed and/or amended from time to time to include any new obligations or arrangements in the way we process your personal data as a means to ensure compliance with any applicable laws and regulations. You will be notified of any important amendments to this Privacy Policy through the usual communication channel.
We encourage you to carefully read this Privacy Policy together with any other privacy statement or fair processing notice we may provide you with on specific occasions in the process of collecting or processing your personal data. It is important that you read this Privacy Policy so that you are fully aware of all logistics re your personal data. This Privacy Policy supplements any and all other notices that we may provide you with from time to time and is not intended to override.
FXTM is responsible for the collection of your personal data in the manner described herein.
FXTM includes the following companies and their respective affiliates and providers (collectively the "FXTM Entities" and each an “FXTM Entity”).
Company | Address | Contact Details |
---|---|---|
Exinity UK Limited | 1 St. Katharine’s Way, London, England, E1W 1UN | dpo@exinity.com +44 (0) 20 3514 1251 |
Exinity Limited | 5th Floor, 355 NEX Tower, Cybercity Ebene, Republic of Mauritius | dpo.mu@exinity.com +44 203 734 10 25 |
Exinity Capital East Africa Limited | Kiganjo House, Rose Avenue, Kilimani, P.O. Box 50719 – 00200 Nairobi, Kenya | dpo.ke@fxtm.com +254 207 640415 |
Your personal data will be controlled by the relevant FXTM Entity that provides services to or is in electronic communication with you. In some instances, your personal data will be controlled by and or exchanged between more than one FXTM Entity, as applicable.
Any enquiries about our use of your personal data should be addressed to the above contact details of the Data Protection Officer.
Personal data includes any and all information which an individual can be identified with and does not include any data where identity has been removed (namely, anonymous data). Upon registration with FXTM, it is necessary that we collect your personal data in order to comply with legal obligations such as KYC and other regulatory requirements. By understanding your background and needs, we can treat you fairly, provide you with the services that best match your requirements, offer you appropriate and relevant information and process your requests in a fair and efficient manner.
We will collect, use, store and transfer different kinds of your personal data which we have grouped together as follows:
We may also collect, store and use the following sensitive types of Personal Information:
We also collect, use and share aggregated data such as statistical or demographic data. Non-personal data may be derived from your personal data but is not considered personal data for the purposes of law as such does not directly or indirectly reveal your identity in any way whatsoever. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website and the Electronic Services feature. However, if we combine or connect aggregated data with your personal data in a way that, either directly or indirectly, identify you we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We use different methods for collecting your personal data such as:
We may use your personal data for the following purposes ("Permitted Purposes"), based on the following legal grounds:
We will use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law (in which case your knowledge or consent for use thereof is not required). If you wish to get an explanation as to how the compatibility of the reason and the original purpose is determined, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you accordingly and explain the legal basis which allows us to do so. Please note that we may process your personal data where this is required or permitted by law.
We may share your Personal Information in the following circumstances:
Some of FXTM Entities and our external third parties are based outside of your home country so processing of your personal data may involve a transfer of data outside your home country for the Permitted Purposes.
Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
If you instruct FXTM to cease using or processing your personal data, FXTM has the right to terminate any existing services to you immediately (or within a reasonable time, as determined by FXTM).
FXTM has put in place appropriate security measures to protect the security of its clients’ personal data and prevent any unauthorised or unlawful processing, accidental loss, destruction, alteration, disclosure or damage of clients’ personal data. FXTM implements appropriate technical and organisational measures such as network traffic encryption, pseudonymization, data encryption, two-factor authentication, access management procedure, tokenization, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc. FXTM limits access to the clients’ personal data to those employees, agents, contractors and other third parties who have a business need to know, only process clients’ personal data on FXTM instructions and are subject to a duty of confidentiality.
We record, monitor and process any telephone conversations and/or electronic communications between us through fax, email, social media or electronic messages, either initiated from FXTM or you. All communications are recorded and/or monitored and/or processed by FXTM, including any telephone conversations and/or electronic communications that result or may result in transactions or client order services even if those conversations or communications do not result in the conclusion of any arrangements and or transactions. The content of any in person conversations and/or communications with you may be recorded by minutes or notes. Any such records can be provided to you upon request at the same language as the one used to provide services to you.
We will retain your personal data for as long as necessary to fulfil the purpose we collected it for, including the purpose of satisfying any legal, accounting or reporting requirements. In order to determine the appropriate retention period for your personal data we consider, among others, any statutory or regulatory retention periods, the amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, applicable legal requirements etc.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact the Data Protection Officer through the email or telephone number available above.
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.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer 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.
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.
If you have any questions that have not been covered in this Privacy Policy, any further concerns regarding the use of your personal data or any complaints regarding this Privacy Policy and the use of your Personal Information, you can reach out to us using the contact details provided above or on our website.
If your complaint or concern is not resolved, you can contact the office of the data protection authority of your home country via their website or the details provided below: