30th December 2016

FXBULLS

Privacy Policy

Our Commitment
FXBulls is authorised for the conduct of investment business. As part of our day-to-day business, we need to collect personal information from our customers and potential customers to ensure that we can meet their needs for a range of financial services and provide them with information about our services. FXBulls fully respects your right to privacy and is committed to protect the privacy of your personal and financial information. This policy confirms how we manage the information provided by
you or a third party in connection with its provision of services to you, or which it collects from your use of its services via their website.
If you have any questions about this policy or how we collect and use personal information about you, please contact us using the contact provided on this website.
Data Protection Law
Data protection law says that the personal information we hold about you must be:
➢ Used lawfully, fairly and in a transparent way;
➢ Collected only for valid purposes that we have clearly explained to you and not used in any
way that is incompatible with those purposes;
➢ Relevant to the purposes we have told you about and limited only to those purposes;
➢ Accurate and kept up to date;
➢ Kept only as long as necessary for the purposes we have told you about;
➢ Kept securely.
Personal information we collect
If you are an actual or potential client, we may collect the following types of information about
you:
➢ Name, address and contact details;
➢ Date of birth and gender;
➢ Information about your income and wealth;
➢ Profession and employment details;
➢ Trading performance;
➢ Any other similar information.
We obtain this information in several ways through your use of its services or other dealingswith it, including through our website, account opening applications, our demo sign-up forms and in the course of ongoing customer service correspondence.
We also keeps a record of your trading behaviour, including a record of:
➢ Products you trade with it and their performance;
➢ Historical data about the trades and investments you have made, including the amount
invested; and
➢ Your preference for certain types of products and services.
We may record any communications, electronic, by telephone, in person or otherwise, that it may have with you in relation to the services provided to you and our relationship with you. These recordings will be the sole property of FXBulls and will constitute evidence of the communications between us. Such conversations may be recorded without the use of a warning
tone or any other further notice.
How we collect and store information
Our use of information is a function of what you provide and what is necessary to carry out some of its services for you. At all times, we will only process an appropriate amount of your relevant information and in line with your rights. Information will be collected and held when you complete an online application or other type of form or access and trade on your account through the website or another service provided to you. The information you give us may include (but is not limited to) your name, address, date of birth, passport number, tax identification number, email address, telephone number, employment
and income information, transaction history and financial statements.
Our website uses cookies which enable clients or visitors to the site (“users”) to navigate around the website and, where appropriate, to enable us to tailor the content to fit the needs of users. Cookies also provide us with generic statistics enabling it to improve the website and to provide you with information about products and services which may be of interest to you. This does not affect your right to opt-out from receiving marketing material. Most browsers are initially set-up to accept cookies, but you can change your cookie preferences if you wish. Your navigation of the client login area may also be less efficient if your browser is set to disable persistent cookies (i.e., those which remain permanently on the cookie file of your computer).
Please visit http://www.allaboutcookies.org/manage-cookies/ for more information on how cookies work and how they may be managed.
You acknowledge and agree that your personal information may be transferred within or outside the Hong Kong area. Please note, we will only transfer personal information to organisations outside the HK area if it has assessed the organisation as having appropriate controls and safeguards in place to protect your personal data.
Reasons for collecting personal information
We collect certain personal information so that it may meet the needs of its clients. We will use this information for the following purposes:
To verify your identity and establish and manage your account
We will need to verify your identity to set you up as a customer and it will need to use that information to effectively manage your account with us to make sure that you are getting the best possible service.
This could include third parties carrying out credit or identity checks on behalf of us, for the specific purpose of anti-money laundering, credit assessment, identity verification and fraud prevention.
We have a legal obligation to comply with certain “Know Your Customer” regulatory obligations and therefore it is in our legitimate interest to gather this information.
To provide you with products and services and to review your ongoing needs
When you open an account with us, it will use your personal information to perform its services and comply with its obligations to you. We also has an obligation to make sure it is providing the best products and services to you and may therefore periodically review your needs to ensure the products and services you receive from us are still the best for you.
To investigate or settle enquiries or disputes
We may need to use personal information collected from you to investigate issues and/or settle disputes with you.
To comply with applicable law or regulatory authorities
We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority.
Data Analysis
Our web pages and emails may contain tags or other similar type of data analysis tools which allow it to track receipt of correspondence and to count the number of users that have visited their webpage or opened its correspondence. Where your personal information is not in an anonymised
Marketing by us
We may use your personal information to send you marketing communications by email, phone or other agreed forms to make sure you are always kept up to date with its latest products and services.
You may tell us if you do not wish to receive marketing material by emailing us. We will process this information fairly and lawfully and will store this information in accordance with relevant data protection legislation.
Record Keeping
We may need to process your personal information for record keeping purposes. Such processing is required to comply with its legal obligations and may include any communications that it has with you in relation to the services provided to you and FXBull’s relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with it.
Corporate restructuring
If FXBulls undergoes a corporate restructure or part or all of its business is acquired by a third party, it may need to use your personal information in association with that restructure or acquisition. Such use may involve disclosing your details as part of a due diligence exercise. FXBulls will only use your information in this way provided it complies with any legal obligation it has to
you.
Security
To maintain a safe and secure working environment, should you enter the premises, we may record your image on its CCTV for security reasons. We may also take your details to keep a record of who has entered their premises on any given day.
Sharing your personal information with third parties
FXBulls may be required to provide your personal information to government bodies from time to time and other countries.
FXBulls may also disclose your personal information to:
➢ Financial institutions and other similar organisations that it deals with in the course of its
corporate activities, or those that are nominated by you;
➢ External service providers (which may be located overseas) that provide services to the
Firm;
➢ Any organisation at your request or any persons acting on your behalf, including your
financial adviser, broker, solicitor or accountant;
➢ Any third parties where this is necessary to process a transaction or provide services which you have requested; or any authority to whom FXBulls are required to disclose such information by law.
Your Rights
Data protection law gives you a number of rights when it comes to personal information we hold about you. These are listed below.
Clear, transparent and easily understandable communication
We must provide in a clear, transparent and easily understandable way how we use your personal information and about your rights. This policy provides that information. The key rights are set out below.
Access to Personal Information
You can ask us if it is processing your personal information and obtain from it a copy of that personal information.
Rectification of Personal Information
If the personal information the Firm holds about you is inaccurate or incomplete, you are entitled to have it rectified.
Removal of Personal Information
You can ask FXBulls to delete or remove your personal information in certain circumstances, such as where FXBulls no longer needs it, or you withdraw your consent (where applicable), provided that FXBulls has no legal obligation to retain that data.
Such requests will be subject to any retention limits FXBulls is required to comply with in accordance with applicable laws and regulations.
Transfer of Data
You have the right, in certain circumstances, to obtain personal information you have provided FXBulls with and to reuse it elsewhere or ask FXBulls to transfer this to a third party of your choice.
Objection
You can ask FXBulls to stop processing your personal information, and it will do so, if FXBulls is:
➢ Relying on its own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
➢ Processing your personal information for direct marketing. Please note, this will not stop the Firm from storing your personal information.
Restriction
You can request a restriction of the processing of your personal information. This enables you to ask FXBulls to suspend the processing of personal information about you.
Withdrawal of consent
In the limited circumstances that FXBulls is relying on your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Once FXBulls has received notification that you have withdrawn your consent, it will no longer process your information for the purposes you originally agreed to, unless FXBulls has another legitimate interest in doing so.
Lodge a complaint
If you think that FXBulls is using your information in a way which breaches data protection law, please contact FXBulls in the first instance using the contact details above. You also have the right to raise a complaint with your national data protection supervisory authority.
Data Security
We take security very seriously and adopts industry and information security best practices to protect your personal information. Measures include strong authentication mechanisms and secure access to machines and data. We have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. It will only process your personal information on FXBulls’s instructions and they are subject to a duty of confidentiality.
Your consent
By accessing this website, or other services we provide to you, you consent to us collecting, maintaining, using and disclosing personal information about you and provided by you or by another person as described in this policy.
Amendments to Policy
From time to time, we may make changes to this Privacy Policy for any reason and will notify you of such changes by posting an updated version of this policy on this website, or where appropriate, by email. You are responsible for regularly reviewing this Privacy Policy and if you use this website or other service FXBulls provides to you after any changes are published, any such use shall constitute your agreement to those changes.