Privacy Policy

Last updated: 17 May 2018

 

FX COMPARED PRIVACY POLICY

Scope of this Policy

This Privacy Policy (“Policy”) applies to the online FX Compared Service at www.fxcompared.com (the “Service”).

The Service is operated by FX Compared Limited a company incorporated under the laws of England and Wales (registered No. 05881052) whose registered address is at 92-93 Great Russell Street, London, WC1B 3PS ( “us” or “we“). Our data protection registration number is ZA083420.

This Policy sets out the principles that govern the collection, use, storage, disclosure and disposal in connection with the Service of personal data of our users and of other members of staff of subscribing organisations (collectively referred to as “you“) by us and our subsidiaries, parent companies and other affiliates and by our subcontractors, service providers, representatives and agents where they act for or on behalf of us ( “our Related Parties“).

The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we collect and process your personal data. The following is a brief summary of our privacy practices.

This Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymised data, aggregated data, or coded data which, in a given form, cannot effectively be used to extract your personal data) (“Anonymised and Aggregated Data“). We reserve the right to generate Anonymised and Aggregated Data extracted out of any databases containing your personal data and to make such use as we sees fit of any such Anonymised and Aggregated Data.

Who is responsible for processing your personal data?

We are responsible for the processing of your personal data insofar as we collect it as part of the Service, through registration forms, surveys, questionnaires or by tracking your use of the Service.

If you have any questions, a request or wish to make any complaint in relation to our use of your data, please contact our data protection officer (“DPO”), who is:

Name: Dan Spiegel

Email: dpo@fxcompared.com

Address: 92-93 Great Russell Street, 2nd Floor, London, WC1B 3PS
 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (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.

What information do we collect about you?

The Service may collect and use both personal data and information about your use of the Service that is not identifiable to you personally:

1.    Personal data that you may give to us or to our Related Parties in connection with your subscription for the Service, for the purpose of signing-up to the Service or accessing or using the Service or in any comment you leave on or through our website. This may include your name, your  address, telephone, email or other contact details, your date of birth, your, information relating to the equipment you use to access the Service (such as MAC numbers and IP addresses), and to the location of that equipment and information you have submitted when searching for or comparing money transfer services.

2.    Information provided to money transfer providers accessed from our Service for the purpose of completing money transfers relating to the initial money transfer and any future money transfers made through that money transfer provider. This information may include, for example, your name, customer ID numbers, referral dates, currency and margin information relating to your transfer, location information and other Anonymised and Aggregated Data.

3.    Non-personal data including technical information such as the type of Internet browser you use, the date and time you access the Service, your Internet protocol address, which pages you view on the Service, length of visits to certain pages and page interaction information (such as scrolling, clicks and mouse-overs) and information regarding methods used to navigate away from the page.

4.    Information collected as part of the services we deliver such as information about your use of the Service.

5.    Information that you have given in order to enter a completion, promotion or survey or other feature provided by us.

6.    In addition, users may post information to the Service which may include personal data.

7.    Information provided to our Related Parties.

8.    Information gathered from communications with or from you (whether by phone, email or otherwise) and regarding any complaint, problems, enquiries and other feedback you may submit (through the website or otherwise).

The purposes for which we collect your personal data

We collect your personal data for the following purposes:

1.    to search and analyse information provided to us by our transfer providers in order to obtain the best quotes and comparisons for you;

2.    to carry out all obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you requested from us;

3.    to conduct analysis designed to improve the way in which we market the site, any advertising and offer we serve to you and others, and to deliver any relevant advertising and products to you;

4.    to provide you with information about other products and services we offer that are similar to those that you have already used or enquired about;

5.    to verify that the transfer provider will be able to perform your money transfer request;

6.    to email you to send you confirmation of the quote selected;

7.    to email you to let you know if the transfer provider that you have selected is unable to perform the trade in accordance with your request;

8.    to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we may contact you by electronic means with information about goods and services similar to those which were the subject of a previous FX transaction or negotiation of any FX trades. If you are a new customer, and where we permit selected third parties to use your personal data, we (or they) will contact you by electronic means only if you have consented to this. 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 tick the relevant box situated on the quotation request form. Please do bear in mind that by opting out, we will not be able to contact you about products or services that may benefit you;

9.    for general accounting and auditing purposes, including the verification of customer transactions completed or aborted with transfer providers;

10. to notify you about changes to our service;

11. to ensure that content from our site is presented in the most effective manner for you and for your computer or portable electronic device;

12. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

13. to improve our site to ensure that content is presented in the most effective manner for you and for your electronic device;

14. to allow you to participate in interactive features of our service, when you choose to do so;

15. as part of our efforts to keep our site safe and secure;

16. if we start to include any advertising to measure or understand the effectiveness of advertising we serve to you and others;

17. to deliver relevant advertising to you; and

18. to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

When do we disclose your personal data to third parties?

We share your personal data with our Related Parties that provide services to us. This includes for example:

1.    transfer providers;

2.    subcontractors or service suppliers that we use to assist us in delivering the Service (including administration services, technical services relating to the maintenance, servicing and upgrading of the Service hosting services, data migration services and analytical services, marketing and customer service, payment processing services, and other outsourced services);

3.    service providers that help us to test, monitor, improve and develop the Service; and

4.    service providers and affiliates who help us compile, aggregate and analyse personal data in order to produce Anonymised and Aggregated Data that we use, sell and publish.

We ensures that such Related Parties do not use your personal data for any other purposes, that they do not disclose it to any other third parties and that they do not retain copies of your personal data except as necessary to provide services to us or to our customers or as may be required by law.

Our affiliates may have access to your personal data for the purpose of performing analytical studies and research. We will not disclose the results of such analysis or research to third parties or publish it except in the form of Anonymised and Aggregated Data.

We also reserve the right to disclose and transfer your personal data to other entities in connection with the sale or transfer of our business or those business activities relating to the Service or other products or services provided to your organisation (including, where necessary, in negotiations towards such sale or transfer).  We will ensure that such acquirer will continue to process the personal data in accordance with this Policy (as it may be updated from time to time).

Other circumstances in which your personal data may be used or disclosed include the following:

1.    if we believe that such disclosure is reasonably necessary to enforce or apply the terms and conditions of a contract with a subscriber organisation or to protect our rights, property, the safety or integrity of our services, software or products, or otherwise as provided by law or required by any court of competent jurisdiction or any regulatory authority acting under statutory powers.

2.    where necessary to satisfy a legitimate request or order of a government body, public authority, regulator or enforcement agency, in response to a third-party subpoena (if on legal advice such response is required); or if necessary to defend us or our subscribers (for example, in a lawsuit).

We will fully co-operate with regulators, law enforcement agencies and other authorities to identify anyone who uses our products, service or software for illegal activities. We reserve the right to report to regulators and law enforcement agencies any activities that are believed to be unlawful.

How do we protect your personal data?

We use appropriate technical and organisational measures to protect your personal data including:

1.    security measures including encryption, firewalls and physical security for our servers and information centres;

2.    limiting and controlling access to records of personal data to members of staff and Related Parties that require such access to perform their duties and services, through passwords, variable log-in rights and other technical and organisational access controls;

3.    ensuring confidentiality obligations are put in place when dealing with our Related Parties and other third parties;

4.    avoiding the collection or storage of personal data when it is unnecessary or for longer than reasonably needed or legally permitted or required and deleting it (or anonymising it) once we no longer need it or are no longer required to keep it as personal data; and

5.    seeking to keep your personal data up-to-date and correct.

However, we cannot guarantee that such protection will always successfully prevent attempts to gain unauthorised access, corruption or loss of personal data. Please bear in mind that transmissions over the Internet are not completely secure, and any information you send to or from this Service may be accessible by others. More specifically, email sent to or from the Service may not be secure.  As a result, Users and organisations should take particular care in deciding what information to send or post to the Service.

Any passwords, ID numbers, or other special access numbers you might use to access any part of this Service are your responsibility; take care to safeguard them.

Data on children

Persons under the age of 16 should not transfer personal data to us unless they have the consent of their parent(s) or guardian(s). We do not knowingly collect, nor do we want to receive, personal data about individuals who are under 16 years of age.

Special categories of data

We do not seek to collect, store or process as part of the Service nor do we wish to receive any personal data relating to individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data or data concerning a person’s sex life or sexual orientation.

Transfer of personal data across borders

Personal data you provide to us through the Service is provided to us in the UK. We may use servers and cloud services to store data in other territories and may transfer the data to other territories for the purpose of storage and data management. Our Related Parties may have access to your personal data in different countries including, without limitation, the UK, the EU and the USA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·      We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

·      Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

·      Where we use providers based in the US, we may transfer data to them if they are part of the “Privacy Shield” which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Retention of personal data

We keep records of personal data collected through the Service for limited periods of time and only as may be reasonably necessary for the purposes for which the data is collected. It is possible personal information may remain on a backup media even if deleted for any legal, tax or regulatory reason.

Links to Third Party Websites

The Service may contain links to other websites. When you click on one of these links you are being transferred to a website operated by someone other than us. The operator of that website will have a different privacy policy. We do not share your personal data with these third party websites and is not responsible for their individual privacy practices. We encourage you to investigate the privacy policies of any such third parties.

Contacting us about privacy questions or concerns

If you have any questions about this Policy, or any queries, requests or complaints in regard to the use of your personal data, please contact our DPO.

If you request changes to the information we have on file for you — this could be the case if you believe that some information we have about you is incorrect, or there is some information about you that has changed (for example, if you no longer use a former email address) — please contact our DPO with the headline “PRIVACY REQUEST” in the message line.

Legal rights

Insofar as we collect your personal data in the European Union, under certain circumstances you have rights under data protection laws to:

·      Request access to any personal data we hold about you.

·      Request that we correct any personal data we hold about you.

·      Request that we delete any personal data we hold about you.

·      Object to us processing your personal data.

·      Request restrictions on our processing of your personal data.

·      Request a transfer of your personal data to a third party data controller.

·      Right to withdraw any consent given to our processing of your personal data.

If you wish to exercise any of the rights set out above, please contact our DPO.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Privacy Policy changes

This Policy was last changed on 17 May 2018. If we make changes to the Policy, the new version will be posted on the Service. We may change, modify, add or remove portions of this Policy at any time, and any changes will become effective immediately upon being posted unless stated otherwise.

 

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Email us:

support@fxcompared.com

Call us:

+44 207 871 5565 (UK)
Mon-Fri 10am-6pm (UTC)

+1 212 600 8553 (US)
Mon-Fri 10am-6pm (EDT)

FXcompared.com is an fx money comparison site for international money transfer and to compare rates from currency brokers for sending money abroad. The website and the information provided is for informational purposes only and does not constitute an offer, solicitation or advice on any financial service or transaction. None of the information presented is intended to form the basis for any investment decision, and no specific recommendations are intended.  FXC Group Ltd and FX Compared Ltd does not provide any guarantees of any data from third parties listed on this website. FX compared Ltd expressly disclaims any and all responsibility for any direct or consequential loss or damage of any kind whatsoever arising directly or indirectly from (i) any error, omission or inaccuracy in any such information or (ii) any action resulting therefrom.