Alpha FX Group plc and its subsidiary Alpha FX Limited (collectively “we”, “us” or “our”) are committed to protecting and respecting your privacy. This policy (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Personal data means information about you from which we can identify you (either on its own, or by piecing it together with other information) (“Personal Data”).
This policy applies to our website www.alphafx.co.uk (which includes any microsites or subsections of this website which are hosted within our web environment) and to any services, including our online platform, which we make available to you through our website (our website and services together are referred to in this policy as the “Website”). Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 19/04/2017.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Alpha FX Ltd, 5th Floor, Brunel House. Reading, RG1 1LG.
Information we may collect from you
On our Website we may collect and process the following data about you:
- Information that you provide by filling in forms on our Website. This may include information provided at the time of registering to use our Website, subscribing to our service, posting material or requesting further services;
- Information that we ask you to provide to us when you report a problem with our Website;
- Information that you provide if we ask you to complete surveys that we use for research purposes, although you do not have to complete these surveys if you do not want to;
- Details of transactions you carry out through our Website and details of the fulfilment of your currency requirements;
- Details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
- Name and job title;
- Contact information including email address; and
- Demographic information such as postcode, preferences and interests.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping;
- We may use the information to improve our products and services;
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided; and
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
IP addresses and cookies
What exactly are cookies?
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through websites may not function properly if your cookies are disabled.
Cookies can be first party or third party cookies:
- First party cookies – cookies that the website you are visiting places on your computer.
- Third party cookies – cookies placed on your computer through the website but by third parties, such as, Google.
Cookies help us to improve our Website and to deliver a better and more personalised service. They enable us to:
- Estimate our audience size and usage pattern;
- Store information about your preferences, and so allow us to customise our Website according to your individual interests;
- Speed up your searches; and
- Recognise you when you return to our Website.
The cookies placed on our Website
We use the following cookies on our Website:
- Strictly necessary cookies – These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
- Performance cookies – These cookies collect information in an anonymous form about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it and the approximate regions that they are visiting from. These are first party cookies.
- Functionality cookies – These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.
These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
- Targeting or advertising cookies – These cookies allow us and our advertisers to deliver information that is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our Website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- Social Media cookies – These cookies allow you to connect with social media networks such as LinkedIn and youtube. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- IP Tracking cookies – We use IP Address tracking technology to identify businesses visiting our site and the pages that are being used.
We may combine information from these types of cookies and technologies with information about you from any other source.
Cookie consent and opting out
If you are located in the European Economic Area (“EEA”) and use our Website, when you arrive on our Website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click “I understand”. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our Website. For more information please visit www.allaboutcookies.org and www.youronlinechoices.com/uk/.
Where we store your Personal Data
The internet is global, so your Personal Data may be transferred in transit outside of the European Economic Area (“EEA”). Our business also operates globally and so it may be necessary to transfer your personal data to other companies within our group of companies located in countries outside of the EEA in particular to Canada. Countries outside of the EEA may not have similar protections in place regarding your Personal Data and its use as set out in this policy. However, we have taken the steps outlined below to try and protect the security of your Personal Data and comply with our legal obligations in relation to the transfer of your Personal Data to non-EEA countries.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any data transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How we use your Personal Data
In all circumstances the Personal Data we hold about you will be adequate, relevant and not excessive. Details of your legal rights in relation to your Personal Data can be found on the Information Commissioner’s website www.ico.org.uk.
We will only process your Personal Data, in accordance with applicable law, for the following purposes:
- To ensure that content from our Website is presented in the most effective manner for you and for your computer;
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To carry out our obligations arising from any contracts entered into between you and us;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To notify you about changes to our service;
- We may also use your Personal Data, or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, telephone or electronic means (e-mail or SMS);
- To search Fraud Prevention Agencies’ records (including information from overseas) and carry out fraud and credit checks (we may pass your details to a third party to carry out these functions);
- To process transactions and prevent fraudulent transactions (we may retain your details for these purposes for a reasonable period of time and we may pass your details to a third party to carry out these functions); and
- To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
If you are an existing customer, we will only contact you by telephone or electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, please indicate it on the form on which we collect your Personal Data (the contact registration form).
Disclosure of your Personal Data
There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with applicable law and for the purposes listed above. These scenarios include disclosure:
- To any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985;
- To our professional advisors;
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets (including by disclosing your Personal Data to potential investors as part of a pre-marketing roadshow);
- If we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of Alpha FX Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction;
- To our outsourced service providers or suppliers to facilitate the provision of our services, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, or to our webhosting provider through which your Personal Data may be collected;
- To third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- To public authorities where we are required by law to do so; and
- To any other third party where you have provided your consent.
Retention of Personal Data
Your Personal Data will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable local law. Please contact us for further details of applicable retention periods.
We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at email@example.com.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites 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.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Intellectual property rights
All intellectual property rights in our Website, any advertising material issued by or on behalf of Alpha FX, all information, materials, prices or charts, business methods, databases or settlement specifications relevant to the provision of our Website or otherwise used or arising in connection with our Website will remain our property and you will have no rights to distribute, republish, copy, reproduce, sell, sub-license or otherwise transfer or disseminate any of the foregoing unless otherwise agreed by us in writing.
We digitally record all telephone conversations with our clients.