Privacy policy

What is the purpose of this policy?

The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity.

We are the controller of any personal information that you provide to us, which means that we decide the purposes and means of the processing of that personal information.

How do we obtain and store your personal information?

We obtain your personal information through applications, emails, letters, telephone calls, text messages, cookies, and conversations when you register in our services and work with them (including the personal information gained when you use our learning tools, demo accounts, and trading simulators).

We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications we send or receive.

We follow strict security procedures in the storage and disclosure of the personal information that you have given to us to prevent unauthorised access.

What types of personal information do we collect and process?

We may process the following types of personal information:

• name
• contact details including email details and phone numbers
• age or date of birth
• gender
• occupation
• income
• trading knowledge and experience
• user names and passwords
• information related to your trading account including your account history, activity, and orders
• IP address
• national insurance number
• transaction reporting reference
• power of attorney/agent details
• phone device type
• operating system
• device ID
• cookie ID
• information about your use of our services, products and facilities.

How do we check your identity?

To comply with money laundering regulations, we need to confirm the name and address of our clients and certain third parties. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit. Our search is conducted with the use of all necessary security measures in order to make sure that the personal information we get is strictly confidential, and unauthorised parties cannot access it.

How do we use your personal information?

As well as checking your identity, the personal information we hold may be used for:

• considering any of your applications
• carrying out risk assessments
• complying with our legal and regulatory obligations
• performing our obligations under any contract we have with you
• administering our relationship with you including resolving queries or issues
• establishing and managing your account
• establishing and managing your account
• reviewing your ongoing needs
• providing you with the information, products and services that you request from us
• checking your instructions to us
• investigating any complaint, you may make
• providing evidence in any dispute or anticipated dispute between you and us
• recovering amounts payable
• training our staff
• enhancing our customer service and products
• undertaking product development and analysis
• detecting or preventing fraud or other crimes
• Google Ads conversion tracking
• Google Analytics
• Facebook Ads conversion tracking
• contacting you - we may send you marketing material from time to time by post, email, telephone, SMS, mobile push notifications, web push notifications, messengers and other electronic messaging services.

When may we share your personal information?

We may share your personal information with:

• relevant regulatory or tax authority
• such third parties as we reasonably consider necessary in order to prevent crime, for instance, the police
• our associated companies
• third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you
• our introducing brokers and other commercial partners
• our professional advisers
• our auditors for the purposes of carrying out financial and regulatory audits
• our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting, and fraud prevention checks
• courts, tribunals, regulatory or tax authorities, and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority, or government agency
• our trade repository
• other parties which may be necessary to involve in order to provide the best service to you as our customer.

Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy and comply with the data protection principles and this policy.

What is the legal basis for our processing of personal information?

The legal basis for our processing of personal information will depend on why we process your personal information.

Where you wish to enter into or have signed a contract to receive services from us, we will process your Personal information to enable us to enter into and perform our contract with you. If you do not provide the personal information requested, we may not be able to provide some or all of those services to you.

We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to performing anti-money laundering, terrorism prevention, and sanctions screening checks, complaints, and investigations or litigation.

We also have a legitimate interest to process your personal information for:

• performing the services or supplying the products or information you have agreed to receive from us
• ongoing management of our relationship with you and to maintain contact with you
• our internal business purposes which may include business and disaster recovery, document retention/storage, IT service continuity (for example, back-ups and helpdesk assistance) to ensure the quality of the services we provide to you
• corporate transactions
• marketing analytics including marketing campaign optimisation and web analytics to enable us to develop and target the marketing of our products and services
• keeping our records updated and studying how customers use our products/services
• developing our products and services, growing our business, and informing our marketing strategy
• portfolio analysis and experience studies to enable us to improve the products and services we offer to customers.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

What is a Cookie and why do we use it?

Cookies are small pieces of information that are stored on your computer by a website you visit in order to enable you to perform certain functions on the website and regulate its content to your preference. They can store data on the pages for which you have provided key information (for example, when you provide a password), but only once you are asked and you accept the storage of this information. Cookies may be used on some pages of the site for us to provide you with a more customised web browsing experience. They are not used to determine the personal identity of anyone merely visiting the site.

Types of cookies we use:

Session cookies.

These cookies are temporary cookies as they are deleted as soon as you close your browser. Session cookies are used to retain the information you provide us with as you navigate through each section of our website. You can choose to decline session cookies via your browser’s privacy settings but please note that this may have a negative impact on your browsing experience and particularly if these are declined across all websites.

Analytical cookies.

Analytical cookies may include both temporary and more persistent cookies that we use to track how you use our website and for how long. Analytical cookies do not divulge any identifying information specific to your person but they do help us improve how we provide you with our content. Refer to your browser’s privacy settings on how you can opt out of analytical cookies.

Functional cookies.

Functional cookies record and save your choices in order to provide a more seamless experience across our website. One way functional cookies do this is by remembering your language selection each time you visit us. Refer to your browser’s urgent privacy settings on how you can opt out of functional cookies.

Third-party cookies.

These cookies are used by third parties and mostly by social media websites like Google+, Facebook, or YouTube. Third-party cookies allow us to offer you easy ways to share our content throughout your social media and also present you with the videos we post on YouTube. You can disable the use of these cookies through your browser’s privacy settings but please do note that this will also disable all the functions described above.