Privacy Policy Last updated: 24/02/2024

We, referred to as "Us" or "Our," are dedicated to safeguarding your Personal Data and privacy.

This Privacy Policy has been prepared to inform you of how we manage, collect, store, and use the information you provide in connection with the website FXPremiere (the "Website").

We pledge to uphold the following principles:

• To ensure transparency in the collection and processing of your Personal Data:

We are committed to keeping you fully informed at all times, enabling you to make educated decisions regarding the use of your Personal Data on our Website or when engaging with a third-party trading platform. To achieve this, we employ a range of approaches and methods to provide you with clear details on how your Personal Data is handled, ensuring this information is delivered accurately and in a timely manner.

Moreover, where it is necessary for us to provide you with specific information, we will ensure it is delivered at the appropriate time and place.

We are also happy to address any questions you may have and to provide any clarification you require, subject to legal constraints. To this end, please feel free to contact us by sending an email to: [email protected]

• To process your Personal Data exclusively for the purposes set out in this Policy:

The purposes for which we may process your Personal Data include, among others, making the Website available to you and connecting you with third-party trading platforms (the "Services"), to enhance your experience on the Website, to improve the Services (including the Website), to protect Our rights and interests, to carry out business and administrative activities that support the provision of the Services to Website users, and/or to comply with any legal and/or regulatory obligations.

Moreover, We will process Personal Data about you in order to better understand your individual needs and preferences.

• To allocate substantial resources in honouring your rights regarding your Personal Data:

We dedicate considerable resources to enabling you to exercise your rights as a data subject. You are therefore welcome to contact Us at any time should you wish to review Personal Data held about you, have Us correct it, delete it, cease using it for specific purposes or altogether, or transfer it to you or a third party. We will act on your requests in accordance with applicable law.

• To safeguard Personal Data about you:

Whilst We cannot guarantee the absolute security of Personal Data held about you, We assure you that We employ, and will continue to employ, a comprehensive range of methods and measures aimed at ensuring that Personal Data about you remains protected.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy sets out the types of Personal Data the Company collects about individuals, and the methods by which it is collected, used, shared with third parties, protected, processed, and so forth.

In this Policy, "Personal Data" refers to any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in conjunction with additional information that We hold or have access to.

In this Policy, the "processing" of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organisation, structuring, storage, modification or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

Our Services are intended for a general audience and are not directed at children under the age of 18. We do not knowingly collect or solicit information from anyone under 18, or knowingly permit such individuals to access our Services. Should We become aware that we have collected information about a child, We will take reasonable steps to remove such information promptly.

2. When Do We Collect Personal Data About You?

We collect Personal Data about you whenever you use the Services, engage with our service channels, or visit the Website. On occasion, you will provide Us with Personal Data directly, and in other cases, We will collect Personal Data by monitoring and analysing your interaction with Our Services and/or Our service channels, or receive your data from our third-party partners.

3. No Obligation To Provide Personal Data To FXPremiere And Its Implications

You are under no obligation to provide Us with any Personal Data about you. However, in certain circumstances, not providing such Personal Data will prevent Us from delivering the Services to you, will restrict your use of the Website, and/or may cause the Services and the Website to malfunction.

4. What types of Personal Data do We collect? Personal Data We collect upon each visit to the Website:

This information includes online activity logs and traffic data (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports, and type of browser used), as well as information regarding the device you used. Some of this information may not personally identify you and may therefore not be considered Personal Data.

Personal Data We receive from you: any Personal Data you provide to Us voluntarily when interacting with a third-party trading platform through Us.

Personal Data You specifically provide for submission to third-party platforms to facilitate trading: This includes your full name, phone number, and email address.

5. The Objectives for Processing Personal Data and Their Legal Foundations

FXPremiere handles your Personal Data for one or more of the purposes detailed in this section, each supported by the appropriate legal basis.

FXPremiere will not process your Personal Data unless there is a legitimate legal basis for doing so. The legal bases on which FXPremiere may handle your Personal Data include:

You have given consent for the processing of your Personal Data for specific purposes. This applies when you deliberately share your information through the Website, allowing us to submit it to a third-party trading platform.
Processing is required to serve the legitimate interests pursued by FXPremiere or a third party. For example, this may include improving our Services or managing legal claims.
Processing is necessary to fulfil a legal obligation to which FXPremiere is subject.

If you require further clarification on how processing your Personal Data serves the legitimate interests of FXPremiere or another party, please do not hesitate to contact us by email at any time.

Below, we set out the reasons why we may process your Personal Data, along with the legal justification for each activity:

	Objective	Legal Foundation
1	To forward your information to third parties at your request for engaging in digital and trading activities. We may collect Personal Data about you in order to pass it to third parties, should you explicitly request this.	You have given consent for the processing of your Personal Data for one or more specified purposes.
2	To address your enquiries, requests, and/or concerns Processing of your Personal Data is necessary to respond to any enquiries you may have regarding your use of our Services.	Processing is required for the legitimate interests pursued by the Company or a third party.
3	To fulfil any legal obligations or court and administrative orders We handle your Personal Data to ensure compliance with our various legal responsibilities.	Processing is necessary to meet a legal requirement that the Company is obliged to follow.
4	To improve Our Services We may use your Personal Data to enhance Our Services. This processing includes, among other things, analysing crash logs or any other malfunction reports relating to the Services.	Processing is necessary for the pursuit of legitimate interests by the Company or a third party.
5	To prevent fraudulent activity and misuse of Our Services	Processing is necessary for the pursuit of legitimate interests by the Company or a third party.
6	To carry out and maintain various activities that support the delivery of Our Services Such activities include back-office operations, business development initiatives, strategic planning, oversight processes, and more.	Processing is required to serve the legitimate interests pursued by the Company or a third party.
7	To conduct analyses, including statistical assessments We apply a range of analytical methods, including statistical techniques, to inform decisions across a variety of matters.	Processing is required to serve the legitimate interests pursued by the Company or a third party.
8	To protect Our and third parties' interests, rights, and assets, including the initiation, exercise, or defence of legal claims We may handle your Personal Data to defend Our interests, rights, and assets, or those of third parties, in compliance with any applicable law, regulation, or agreement, including any of Our terms, conditions, and policies.	Processing is required to serve the legitimate interests pursued by the Company or a third party.

6. Transfer Of Personal Data To Third Parties

FXPremiere may also disclose your Personal Data to third-party service providers who support us with storage, hosting, IP address information, user experience analysis, research, and other analytical, technical, and diagnostic services.

Additionally, at your specific request, we may transmit certain Personal Data about you to third-party trading platforms. In such cases, we will share the information you provide for this purpose with those third parties, and they will handle your Personal Data in accordance with their own privacy policies. We may share your Personal Data with several third-party trading platforms.

FXPremiere may also share your Personal Data with its affiliated entities and business partners, who provide resources that enhance the quality of the services and products we offer to our users.

We may disclose your Personal Data to governmental, local, official, and regulatory bodies where such disclosure is necessary to protect our interests, rights, and assets, as well as those of third parties, including the initiation, exercise, or defence of legal claims.

Furthermore, we may disclose Personal Data about you to potential buyers, investors, or lenders of FXPremiere or any company within our group, or in connection with any similar transaction (such as asset sales), or in relation to any merger, reorganisation, consolidation, or insolvency of FXPremiere or any associated company.

7. Cookies and Third Party Services

We may make use of certain third-party services, such as analytics companies or advertising providers on our Website, which may also employ cookies or other technologies. These practices and providers are governed by their own policies.

A cookie is a small text file that is placed on the device you use to visit or access the Website. These cookies enable the collection of information about you and your behaviour, in order to enhance your user experience by remembering your preferences and settings, and by tailoring products and services that may be of interest to you. Cookies may also be used to gather statistics and carry out analytics.

Some of the cookies we may use are session cookies, which are temporarily stored on your device and remain active until you close your web browser. Others are persistent cookies, which remain on your device after you stop browsing the Website, helping the Website to recognise you as a returning visitor.

Types of cookies:

The cookies we may use are categorised according to their functionality as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are essential to enable you to navigate the Website and access the features you have requested. They ensure the delivery of our content, products, and services. Such cookies are vital for your device to download or stream content, enabling seamless navigation through the Website, use of its features, and returning to previously visited pages.	These cookies collect personal data about you, such as your username and last login date, and confirm your login status on the Website. These cookies are automatically deleted once you close your web browser (session cookies).
Functionality Cookies	These cookies enable us to recognise you when you return to the Website, allowing us to remember your choices and preferences.	These cookies remain active even after your browser is closed, until they reach their set expiry date.
Performance Cookies	These cookies are used to gather aggregated statistics about the Website's performance, supporting its testing and improvement to deliver a better user experience. They also enable us to carry out analytical functions on the Website.	These cookies collect anonymised data that cannot be linked to any identified or identifiable individual. The lifespan of these cookies varies; some are deleted when you close your browser, whilst others persist indefinitely.

Blocking and Removing Cookies

You can adjust your browser settings to block or remove some or all cookies. Below are links with instructions for doing so in some of the most widely used web browsers:

Firefox
Microsoft Edge
Google Chrome
Safari

Please note that if you do so, certain features and functionalities of the Website may not function as intended.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

FXPremiere will retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy or as required by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for a period of 12 months and, subject to your consent, may extend this for a further 12 months.

To ensure that your Personal Data is not held for longer than necessary, we regularly review the data we retain to determine whether any can be deleted.

9. Transfers of Personal Data To A Third Country Or An International Organisation

Your Personal Data may be transferred to a third country (i.e., outside of your jurisdiction) or to international organisations. In such cases, FXPremiere will put in place appropriate safeguards to ensure the protection of your Personal Data and to provide enforceable data subject rights and effective legal remedies.

If you reside in the EEA (European Economic Area), please note that these protections and safeguards will apply where any of the following conditions are met:

The transfer is directed to a third country or an international organisation recognised by the EU Commission as providing an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 (commonly known as the "GDPR").
The transfer is carried out under a legally binding and enforceable agreement between public authorities or bodies as set out in Article 46(2)(a) of the GDPR; or
The transfer is in accordance with standard data protection clauses adopted by the EU Commission in line with Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

If you would like to learn more about the safeguards we use to protect Personal Data transferred to a third country or an international organisation, please contact us by email at: [email protected]

10. Protection Of Your Personal Data

We take seriously the implementation of appropriate technical and organisational measures to maintain a high level of security for Personal Data, taking into account the risks associated with processing — in particular, those arising from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data that is transmitted, stored, or otherwise processed.

Whilst we strive for the highest standards, we are unable to guarantee error-free handling of your Personal Data. We disclaim any liability for indirect, incidental, consequential, or punitive damages arising from the use or disclosure of your Personal Data, including but not limited to disclosure resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

In certain circumstances, legal or other obligations beyond our control may require us to transfer your Personal Data to third parties such as public authorities. In such cases, our ability to govern the level of protection afforded to your Personal Data by those third parties is limited.

The transmission of Personal Data over the internet cannot be fully secured. Accordingly, FXPremiere cannot guarantee the security of your Personal Data during its transmission to us via the internet.

11. Links to Third-Party Websites

The Website may contain links to websites and/or applications operated by third parties. FXPremiere does not oversee these websites or applications, nor the collection and/or processing of your Personal Data by them. We accept no responsibility for these websites and applications or their privacy and data protection policies and practices. This Policy does not govern any activities carried out through such websites and/or applications.

Whenever you visit these third-party websites and/or applications, we strongly recommend that you review their privacy policies carefully before using them and before sharing any of your Personal Data.

12. Your Rights Regarding Your Personal Data

In general, you have the right to request that we confirm whether we are processing Personal Data about you, to access this data, to correct any inaccuracies, and to delete Personal Data that we no longer require. You may also limit your consent to specific processing of your Personal Information.

If you are a resident of the EEA, please read this section carefully:

You have the following rights in respect of your Personal Data. To exercise these rights, you may submit a request to the following email address:

Right of Access

You have the right to obtain from FXPremiere confirmation as to whether your Personal Data is being processed and, if so, to access that Personal Data together with the following information: (1) the purposes of processing; (2) the categories of Personal Data involved; (3) the recipients or categories of recipients to whom the Personal Data has been or will be disclosed, particularly those in countries outside the European Economic Area (EEA) or with international organisations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from FXPremiere the rectification or erasure of Personal Data or the restriction of its processing, or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data has not been collected directly from you, any available information as to its source; (8) the existence of automated decision-making, including profiling; and (9) where Personal Data is transferred to a third country outside the EEA or to an international organisation, the appropriate safeguards in place in relation to the transfer.

FXPremiere will supply a copy of the Personal Data undergoing processing and may charge a reasonable fee for any additional copies requested. Where the request is submitted electronically, and unless you indicate otherwise, the information will be provided in a commonly used electronic format.

The right to obtain a copy of your Personal Data must not infringe upon the rights and freedoms of others. Accordingly, where a request would compromise the rights and freedoms of another person, FXPremiere may decline to fulfil the request or may do so only in part.

Right to rectification

You are entitled to require FXPremiere to correct any inaccurate Personal Data held about you. Taking into account the purposes of processing, you also have the right to have incomplete Personal Data about you completed, including by means of a supplementary statement.

Right to erasure

The following grounds apply: (a) the Personal Data is no longer required for the purpose for which it was collected or otherwise processed; (b) you withdraw the consent on which the processing is based and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased in order to comply with a legal obligation under European Union or Member State law applicable to the Company.

This right does not apply where the processing is necessary (a) to comply with a legal obligation requiring processing under European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defence of legal claims.

Right to Restrict Processing

You have the right to request that the Company restricts the processing of your Personal Data in the following circumstances: (a) if you contest the accuracy of the Personal Data, for a period enabling the Company to verify its accuracy; (b) if the processing is unlawful and you oppose erasure, requesting instead that its use be restricted; (c) if the Company no longer requires your Personal Data for processing purposes, but you need it for the establishment, exercise, or defence of legal claims; (d) if the processing is based on the legitimate interests pursued by the Company or a third party, unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent related to such marketing.

Where the processing of your Personal Data has been restricted at your request, such data, apart from storage, will only be processed with your consent or for the establishment, exercise, or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of substantial public interest of the European Union or a Member State.

Right to Data Portability

You are entitled to receive the Personal Data you have provided to the Company in a structured, commonly used, and machine-readable format. You also have the right to transmit that data to another controller where the processing is based on your consent or on a contract to which you are a party, and the processing is carried out by automated means.

When exercising your right to data portability, it may be possible to have your Personal Data transferred directly from the Company to another organisation, provided this is technically feasible. This right is without prejudice to your or the Company's right to erasure. Furthermore, the exercise of this right should not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

You may withdraw your consent for us to process your Personal Data at any time, without this affecting the lawfulness of any processing carried out prior to the withdrawal.

Right to Object

You may object to the processing of your Personal Data at any time, in particular where it relates to your specific situation and where the processing is based on the legitimate interests of the Company or a third party — including any profiling carried out on those grounds. Once you object, we will cease processing your Personal Data unless we can demonstrate compelling legitimate grounds for continuing the processing that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defence of legal claims.

You may also object at any time to the processing of your Personal Data for direct marketing purposes, including any related profiling.

Right to lodge a complaint with a supervisory authority

You are entitled to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons with regard to the processing of Personal Data within the European Union.

Your rights in respect of your Personal Data as set out in this section 13 may be subject to limitations under European Union or Member State law to which the Company is subject.

We will respond to your request in accordance with the rights detailed in this section 13 promptly and within one month of receipt. This period may be extended by up to two additional months where necessary, having regard to the complexity and number of requests. We will notify you of any such extension within one month of receiving your request, together with the reasons for the delay.

Information provided in response to requests made under the rights set out in this section 13 will be provided free of charge, unless otherwise specified in this section 13. Where requests are manifestly unfounded or excessive — in particular because of their repetitive nature — we may either (a) charge a reasonable fee, reflecting the administrative costs of providing the information, communication, or action requested; or (b) decline to act on the request.

FXPremiere may ask you to supply additional information necessary to verify your identity in order to process your request in accordance with the rights set out in this section 13, particularly where there are reasonable grounds to doubt the identity of the person making the request.

13. Updates To This Policy

We reserve the right to amend this Policy from time to time. Whenever changes are made, we will notify you by publishing the updated Policy on the Website. For significant changes, we will also endeavour to notify you through communication channels reasonably likely to reach you, and by posting a notice on the Website. Unless otherwise stated, all changes will take effect upon publication of the updated Policy on our Website.