Alpha FX Limited
Alpha FX is the data controller and is responsible for your Personal Data. Our registered office is at Brunel Building, 2 Canalside Walk, London, W2 1DG, and we are authorised and regulated in the UK by the Financial Conduct Authority.
What types of personal data do we collect?
As described above, “Personal Data” is any information that can be used to identify you or that we can link to you and which we have in our possession or control. Due to the nature of the services we provide, the types of data we collect can be quite varied, but will usually include full names, contact details, and associated client information. Depending on the nature of our relationship with you, we may also collect personal data about you which includes data relating to your identity (including copies of your passport and/or driving licence); financial data; and where offered to us, data relating to your family, education and employment background; the services we provide you or your company; the goods or services you or your company provide us; and your use of our website or any electronic system or interface that we provide to you through our website (the “Online Platform”). We may obtain such Personal Data from you directly or from third parties (including publicly available information). Where you are our client or are providing goods or services to us, it will sometimes be necessary for you to provide us with Personal Data directly, and in those cases, it is your responsibility to ensure that all such Personal Data is complete in all material respects and not misleading. The accuracy and appropriateness of our services may be affected as a consequence of your failure to do so. If any information changes, please let us know so that we can keep it updated on our systems.
How we use your Personal Data
We may do the following with your Personal Data:
- use it to provide foreign exchange and related services to you;
- use it to engage in marketing and business development activity in relation to our services;
- to discharge legal and regulatory obligations;
- use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- record and monitor your use of our websites, or our Online Platform or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
- share it with our professional advisors;
- in the event that we buy or sell any business or assets, or substantially all of our assets are acquired by a third party, we may share your Personal Data to the prospective buyer, and in the event of an acquisition, Personal Data held by us about our clients will be one of the transferred assets;
- use it for our legitimate business interests, such as undertaking business research, direct marketing, analysis, managing the operation of our websites, our Online Platform and our business. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you. If you have any concerns, you have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see the section titled “What are your rights?” below.
- use it to look into any complaints or queries you may have; and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
What basis do we have for processing your Personal Data?
We will only process your Personal Data where we have a lawful basis for doing so. Our lawful basis will be one of more or the following:
- Consent – if we need and have obtained your consent to use your Personal Data. You can withdraw your consent by contacting us.
- Performance of a contract or payment instruction by you – we may need to collect and use your Personal Data for the performance of a contract to which you are party or in order to take steps at your request prior to entering a contract or to process a payment instruction from you.
- Legitimate interest – we may use your Personal Data as is necessary for the purposes of pursuing our legitimate interests (this includes carrying out the business of providing foreign exchange and related services and pursuing our general business interests).
- Compliance with law or regulation – we may use your Personal Data as necessary to comply with applicable law/regulation.
How we share Personal Data with third parties
- in providing services to our clients and in complying with our legal obligations, we may share the Personal Data that we obtain about you, insofar as we are permitted by law to do so, with the following:
- third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Data for the purposes described in this Policy. This may include, but is not limited to, IT service providers such as cloud providers of software as a service, data room providers and providers of our IT servers and communications service providers;
- third parties relevant to the services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, other professional service providers, regulators, authorities, governmental institutions and stock exchanges; and/or
- to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation.
Where we transfer your Personal Data outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the Personal Data.
Retention of Personal Data
How long we hold your Personal Data for will vary and will depend principally on:
- the purpose for which we are using your Personal Data – we will need to keep the information for as long as is necessary for the relevant purpose; and
- legal obligations – laws or regulations may set a minimum period for which we have to keep your Personal Data.
Personal Data Security
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.
What are your rights?
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), in respect of our processing of your Personal Data. Information can be found at 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.
You have rights under data protection laws to request from us access to, rectification of, or erasure of your Personal Data. You also have the right to request the restriction of any processing or to object to our processing of your Personal Data. Finally, you have the right to data portability. Please use the contact details below to exercise your rights. You can find more information about your rights at www.ICO.org.uk.
How to contact us
If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of your rights listed above, please contact us by emailing firstname.lastname@example.org.
We digitally record all telephone conversations.
What exactly are cookies?
A cookie is a small file 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 or link you are clicking places on your computer.
- Third party cookies – cookies placed on your computer through the website but by third parties, such as, Google.
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. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. These are third party cookies.
- IP Tracking cookies – we may use third parties to provide information about visitors to our websites. When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data. These are third party cookies.
- Post-Click Tracking Cookies – These cookies are used to report on the pages of www.alphafx.co.uk that have been viewed by visitors to the site who have followed links placed within email correspondence. This analysis helps us to analyse engagement with content that is viewed by the contacts in our database and therefore allows us to improve it in the future. Since these cookies are paired to individual email addresses, it will be possible for us to identify the activities of the individual who the email address is registered to. These are third party cookies.
We may combine information from these types of cookies and technologies with information about you from any other source.
Cookie consent and opting out
In order to opt out of IP Tracking cookies, Post-Click Tracking Cookies, User journey tracking cookies or Document Tracking Cookies you will need to email email@example.com.