Privacy and Cookie Policy

Privacy and Cookie Policy

This privacy and cookie policy (the “Policy”) explains how Alpha FX Limited collects, uses and shares the information you provide to us and the information we collect in the course of operating our business (the “Personal Data”).

Alpha FX Limited

Alpha FX is responsible for your Personal Data. In this Policy, references to Alpha FX or “we”, “us”, or “our” means Alpha FX Limited. Our registered office is at 2 Eastbourne Terrace, Paddington, London, W2 6LG, and we are authorised and regulated in the UK by the Financial Conduct Authority.

What types of data do we process?

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.  Because of the nature of the services we provide, the types of data we process 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 process information about your business and company affiliations; identification (including copies of your passport and/or driving licence); financial affairs; family, lifestyle and social circumstances; education and employment background; the services we provide you or your company; and the goods or service you or your company provide us; and your use of our website.  In some circumstances we may process special categories of Personal Data about you, in which case we take particular care to only process such data in accordance with the strict legal parameters. This type of data can include information about your health; racial or ethnic origin; religious or political beliefs; trade union membership; sex life or sexual orientation; genetic or biometric data; or philosophical beliefs.  We may obtain such Personal Data from you directly, from our clients and from third parties (including publicly available information).  Where you are our client, it will sometimes be necessary for you to provide us with information directly, and in those cases, it is your responsibility to ensure that all such information is complete in all material respects and not misleading. The accuracy and appropriateness of our service 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 the information we collect

We may do the following with your Personal Data:

  1. use it to provide foreign exchange and related services to the relevant client;
  2. use it to engage in marketing and business development activity in relation to our services;
  3. to discharge legal and regulatory obligations;
  4. use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  5. record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
  6. share it with our professional advisors;
  7. 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 or seller, and in the event of an acquisition Personal Data held by us about our customers will be one of the transferred assets;
  8. use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business.
  9. use it to look into any complaints or queries you may have; and
  10. 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 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 – 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.
  • 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 information 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 information.

Keeping your information and information security

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 regulation may set a minimum period for which we have to keep your Personal Data.

We will ensure that the Personal Data that we hold is subject to appropriate security measures.

What are your rights?

You have the right to lodge a complaint with the Information Commissioner in respect of our processing of your Personal Data. Information can be found at www.ICO.org.uk. If you would like to raise your complaint with us in the first instance, please contact us.

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.

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.

Telephone conversations

We digitally record all telephone conversations.

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 dataprotection@alphafx.co.uk.

Cookie Policy

What exactly are cookies?

In order to collect the information as described in this Policy, we may use cookies and similar technology on our website and emails.

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 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.
  • 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.
  • 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.
  • Document Tracking Cookies – Some documents we send clients uses cookies to track engagement with our documents.  These cookies are also paired to individual email addresses and therefore make it possible for us to identify the activities of the individual who the email address is registered to.

We may combine information from these types of cookies and technologies with information about you from any other source.

Cookie consent and opting out

We assume that you are happy for us to place cookies on your device. However, you may refuse to accept most cookies by activating the setting on your browser which allows you to refuse the setting of cookies.  However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

In order to opt out of IP Tracking cookies, Post-Click Tracking Cookies or Document Tracking Cookies you will need to email dataprotection@alphafx.co.uk.

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 notifying you that we use cookies on our website. You will be deemed to have provided consent to this Policy if you continue browsing our website.   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/.