Security and Disclosure
FXCM Bullion Limited respects each individual's right to privacy. We value our relationship with you, and we take pride in maintaining loyalty and respect with each individual client by providing you with security with respect to your personal information. The provisions of this notice apply to former clients, current clients, and applicants.
- PERSONAL INFORMATION
When you apply for and/or maintain a live or demo account with FXCM Bullion Limited or contact FXCM Bullion Limited for any inquiries, FXCM Bullion Limited collects personal information, including your name, contact details and other personal particulars for the following purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about investment products and services and providing customer service. The types of personal information may include:
- Application information. Information you provide to us on applications and other forms, such as your name, address, birth date, identification card number, occupation, assets, and financials.
- Transaction information. Information about your transactions as well as information about our communications with you. Examples include your account balances, trading activity, your inquiries, and our responses.
- Verification information. Information necessary to verify your identity, such as a passport or driving license. Additional examples also include background information we receive from public records or from other entities not affiliated with FXCM Bullion Limited. FXCM Bullion Limited may also be required to collect your information and take actions necessary to verify your identity in accordance with regulatory requirements.
FXCM Bullion Limited intends to use your name, telephone number and email address for direct marketing investment products and services and FXCM Bullion Limited requires your consent for that purpose. By applying for and/or opening a live or demo FXCM Bullion Limited account, you acknowledge and agree that your consent is voluntarily provided to FXCM Bullion Limited. If you do not wish FXCM Bullion Limited to use your data for use in direct marketing as described in this policy, you may exercise your right to opt-out by notifying FXCM Bullion Limited.
In compliance with the Personal Data (Privacy) Ordinance, FXCM Bullion Limited would like to inform you that your personal information may be used for the following purposes:
- Sharing, cross-checking and transferring that personal data with any of FXCM Bullion Limited's affiliated or associated companies whether in relation to new or existing client verification procedures, ongoing account administration or direct or indirect marketing of any investment, dealing or related services or products;
- The comparison and or transfer to third party service providers of such personal data for the purposes of credit checking and or data verification;
- Any purpose relating to or in connection with the compliance of any law, regulation, court order or order of a regulatory authority, including the provision of any such data to any such regulatory authority as required by law or regulation;
- Any other purpose relating to or in connection with FXCM Bullion Limited's business or dealings or the business or dealing of any of its affiliated or associated companies.
Your personal data held by FXCM Bullion Limited will be kept confidential but FXCM Bullion Limited may provide information to 1) any agent or third party services provider who provides services to FXCM Bullion Limited or any of FXCM Bullion Limited's affiliated or associated companies in connection with the operation of its business 2) any regulatory or governmental authorities which relates to or govern any business of FXCM Bullion or any of its affiliated or associated companies and 3) any person that FXCM Bullion Limited consider as appropriate or fit including a member of FXCM Bullion or its affiliated or associated companies and its employees under a duty of confidentiality. Such information may be transferred to a place outside of Hong Kong where the protection may not be the same or of a similar level to Hong Kong.
In accordance with the terms of the Personal Data (Privacy) Ordinance, any client has the right:
- To determine whether FXCM Bullion Limited holds data about that client and of access to such data;
- To request FXCM Bullion Limited correct any inaccurate data relating to the client;
- To ascertain FXCM Bullion Limited's policies and practices in relation to data and be informed of the kind of personal data held by FXCM Bullion Limited or any of its affiliated or associated companies; and
- To request FXCM Bullion Limited cease from using his/her personal data for direct or indirect marketing purpose by writing.
The Data Protection Officer,
Room 2302 Lee Garden Two,
28 Yun Ping Road, Causeway Bay, Hong Kong
Telephone: +852-3470-9038 Fax: +852-3420-9501
You are not required to supply any of the personal information that we may request. However, failure to provide all required information may prevent us from opening and/or maintaining your account or providing services to you. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
- ABOUT COOKIES
- SECURITY TECHNOLOGY
FXCM Bullion Limited uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone other than FXCM Bullion Limited while it is being transmitted to us. We work hard to ensure that our Web sites are secure and that they meet industry standards. FXCM Bullion Limited also uses other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.
- SHARING INFORMATION WITH OUR AFFILIATES
FXCM Bullion Limited may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new investment products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, transaction and account information. Our affiliates maintain the privacy of your information to the same extent FXCM Bullion Limited does in accordance with this Policy.
If you do not wish to have your personal information disclosed to our affiliates or other third parties as described in this Policy, please contact us via e-mail at: firstname.lastname@example.org, or send your request to:
FXCM Bullion Limited
Attention: Compliance Officer
Room 2302 Lee Garden Two,
28 Yun Ping Road, Causeway Bay, Hong Kong
- SHARING INFORMATION WITH THIRD PARTIES
FXCM Bullion Limited does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with FXCM Bullion Limited, including those that provide professional, legal, or accounting advice to FXCM Bullion Limited. Non-affiliated companies that assist FXCM Bullion Limited in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that FXCM Bullion Limited describes in this policy.
We may also disclose your personal information to third parties to fulfill your instructions or pursuant to your expressed consent.
We want you to know that FXCM Bullion Limited will not sell your personal information.
- REGULATORY DISCLOSURE
- EEA RESIDENTS
The following provisions are only applicable to EEA Residents:
YOUR DATA PROCTECTION RIGHTS
Subject to certain conditions, data protection law provides individuals with rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:
- Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. We will then correct our records, and notify any third parties to whom such personal information may have been transmitted as described above.
- Right to data portability. You may request a copy of all personal information you have provided to us after which we will transmit those data to another data controller of your choice.
- Right to opt-out of marketing communications. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
- Right to withdraw consent. You may withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
- Right to object to processing. You may request that we stop processing your personal information. Please note you may not be able to benefit from certain service features for which the processing of your personal information is essential.
- Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions. Alternatively, you may contact the authority of the country you reside in. Please find further details here.
If you wish to exercise any of these rights, please visit the dedicated page. Please note that you may be required to prove your identity for us to service you. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.
Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review.
We make automated decisions at account opening, where we check that the offered products or services are appropriate for you based on the information you provide to us. For example we may use information about your financial standing or socio-demographic information to assess whether you are appropriate and understand the risk involved when trading our products.
When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by visiting the dedicated page. Please note that you may be required to prove your identity for us to service you.
LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION
Our lawful basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect vital interests.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us.