Your privacy is very important to us. We are committed to protecting and respecting your personal data, ensuring that when you choose us to use our services, you know what data we collect about you and how we use and protect that personal data.
2. WHO WE ARE 2.1 Alianza Fx Limited is a limited company with company number 08965105, whose registered office is at 68 Hanbury Stree, E1 5JL.
2.2 We are an online trading platform which assists retail and institutional investors to trade in the margin foreign exchange market (“Forex”) and other derivative instruments. Our online trading platforms operate through the following website: https://alianzafx.com and the Alianza Fx mobile applications (the “Apps”).
2.3 “customer”, “you” or “your” means an individual who is the subject of the personal data that we process as a data controller.
3.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
4.1 The personal data we collect (or receive) about you may include your: (a) name and address; (b) e-mail address; (c) username, password; (d) your IP address; (e) your phone numbers (which could be your home, work or mobile numbers); (f) credit card details; (g) information relating to an individual’s source of wealth; (h) occupation; (i) bank account details, including institution name, branch, account name, bank identifier; (j) bank account number or IBAN; or (k) information relating to your trading experience.
4 5 www. AlianzaFx.com www. AlianzaFx.com (b) we ask you to complete surveys that we use for research purposes, although you do not have to respond to them; (c) you use and interact with our Website or our Apps including your device’s manufacturer and model, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, web browser, platform, mobile carrier, and your ISP. We may collect details of your visits to our Website or our Apps (including, but not limited to, traffic data, location data, weblogs and other communication data). We do this via email and website cookies, and similar tracking technology built into our Websites and Apps. We make cookie policies available on each of our Websites and Apps to give you more detailed information on how we use them; (d) you use your customer account to login to and use our platform technology and other features and functionalities; (e) you use the online trading products we provide to you. Under no circumstances are these details disclosed to any third parties other than those who need to know this information in the context of the services we provide; or (f) you use social media, including “like” buttons and similar functions made available by social media platforms.
6. HOW WE MAY USE YOUR PERSONAL DATA 6.1 We may process your personal data for one or more lawful bases of processing (“Lawful Basis”) depending on the specific purpose for which we are using your data (see below).
6.2 We may process your personal data for the purpose of: (a) dealing with your inquiries and requests, including contacting you where necessary. Lawful Basis: your consent or performance of our contract with you; (b) notifying you about important changes or developments to our Websites, our Apps or to our products or services (e.g. changes of features or enhancements). Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (c) carrying out our obligations arising from any contracts connected to you. Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (d) providing and personalising our services, enhancing customer experience and tailoring our services to you. Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (e) providing you access to all parts or features of our Websites, our Apps or our services. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
4.2 We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards, set under those laws. Identification documentation, as required under anti-money laundering legislation or other legislation relevant to the services we provide to you, includes: (a) passport; (b) driver’s licence; (c) national identity card (if applicable); (d)
utility bills; (e) trust deed; (f) a credit check on the individual; or (g) other information we consider necessary to our functions and activities.
4.3 Where it is necessary to do so, we also collect data regarding the following individuals: (a) trustees; (b) partners; (c) company directors and officers; (d) officers of co-operatives and associations; (e) client agents; or (f) individuals dealing with us on a “one-off” basis.
4.4 You have the option of not identifying yourself, or of using a pseudonym, when dealing with us in relation to a particular matter. However, we can only provide you with this option when it is not impracticable for us to do so and when no law requires identification.
5. HOW WE COLLECT YOUR PERSONAL DATA 5.1 We may collect (or receive) and process your personal data when: (a) you contact us, whether through our Website, our Apps or otherwise (for example, via our online form, by e-mail, post, fax or phone), as we may keep a record of that correspondence. For example, if you submit a complaint, report a problem with our services or our Websites or our Apps or otherwise liaise with our customer service, technical support or any other department in our company. This includes information provided by you when you update a customer account such as your name, e-mail, country, password, etc;
6 7 www. AlianzaFx.com www. AlianzaFx.com (q) monitoring how people use our Websites and our Apps to see if they are being abused or threatened, for example, by internet trolls posting inappropriate comments in review areas or by would-be hackers looking to undermine our security. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests; (r) allowing us to understand our customer base across all our businesses. We do this by merging your details with information from other customers of our Websites and Apps. We can then spot trends and common factors among customers, plus we can tailor our business approach, our marketing communications, our digital and social media, our websites and mobile apps to the things we believe you and other people like you would be most interested in. This process involves the analysis of many human traits and is sometimes called profiling ‘market segmentation’ or ‘customer segmentation’. Among other things, we look at common trends or ‘segments’ based on people’s geographic location, trading behaviour, online behaviours, engagement with marketing activities (e.g. email opens and clicks), preferences, and any other personal information you have submitted to us or arising from your use of our Websites or our Apps. Lawful Basis: processing is necessary for our legitimate interests; and (s) testing new systems and processes as we roll them out (but generally only in anonymous form) to make sure they work correctly and meet the standards we set for ourselves. Lawful Basis: processing is necessary for our legitimate interests.
6.3 We may take steps to verify the data we collect. For example, a birth certificate provided as identification may be verified with records held by the General Register Office to protect against impersonation, or we may verify with an employer that employment and remuneration information provided in an application for credit is accurate. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests.
6.4 We may check some of the information that you provide to us against third party databases to confirm that it is accurate. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests.
6.5 We may have access to your financial information, such as your billing address, bank account details and payment history in order to allow us to take payments from you in connection with the online trading products you purchase, send you refunds or enable our customer service to deal with your enquiries. Under no circumstances are these details disclosed to any third parties other than those who need to know this information for the performance of the services requested. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests.
6.6 We may also collect social media content where this is in the public domain, and any messages you send direct to us via social media. This information can include posts and comments, pictures and video footage on websites such as YouTube, Facebook and Twitter. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests. (f) where applicable, processing your payments. Lawful Basis: performance of our contract with you or necessary for our legitimate interests or to comply with our legal obligations; (g) administering your registration and/or membership and other customer accounts records. Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (h) market research, analysis and creating statistics. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests; (i) sending you marketing communications, for instance, to contact you from time to time regarding things you have told us you want to hear about, such as new products, special offers, competitions and sponsored events. If you use our Apps, we may use push notifications to highlight when we have added new offers and promotions that may be of interest to you. Lawful Basis: your consent or necessary for our legitimate interests; (j) preventing, detecting and investigating potentially prohibited or illegal activities, and enforcing our Terms and Conditions of Service. Lawful Basis: to comply with our legal obligations or necessary for our legitimate interests; (k) improving and developing our Website, our Apps or our products and services, as well as collecting feedback from you about our Websites, our Apps, and other activities. For example: a. we may need to gauge whether a new product, website feature or App is likely to appeal to a large proportion of our customer base. And if not, we will want to know why; or b. occasionally we may invite you to review a website or App. If we do, it is possible that we will use independent research and feedback providers to act on our behalf. Lawful Basis: your consent or necessary for our legitimate interests; Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (l) ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device. Lawful Basis: performance of our contract with you or necessary for our legitimate interests; (m) ensuring we have adequate security measures and services so you can safely access our Websites and our Apps. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests; (n) complying with all the applicable laws and regulations. Lawful Basis: to comply with our legal obligations; (o) debt recovery or debt tracing, crime, fraud and money laundering compliance. Lawful Basis: to comply with our legal obligations or necessary for our legitimate interests; (p) recruitment purposes if you have applied for a position with us
including to contact you to discuss a role with us and to assess your suitability. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests; 8 9 www. alianzafx.com www.alianzafx.com
7. YOUR CONTACT INFORMATION Where applicable, you can change your contact details at any time by updating your profile within your trading account. You can also update your communication preferences by changing your settings related to your notification choices. 8. DATA SECURITY
8.1 The Internet is not a secure medium. Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the World Wide Web/Internet.
8.3 Where you have been allocated a trading account, this area is protected by your user name and password, which you should never divulge to anyone else.
8.4 We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. For instance, our security measures include, but are not limited to: (a) educating our employees as to their obligations with regard to your personal data; (b) requiring our employees to use passwords and twofactor authentication when accessing our systems; (c) encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks; (d) employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems; (e) using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; (f) practising a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and (g) employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
6.7 If you are an existing customer, we may contact you with information, products or services that you request from us or with information, products or services which are similar to the services we are providing to you (independently or jointly with others), unless you have opted out to be contacted for such purposes. We may contact you for this purpose by post, telephone and SMS as well as by email. If you change your mind about being contacted in the future, please let us know.
6.8 We do not sell, rent, or otherwise provide your personal data to third parties unless you consent to this or it is necessary to provide you with our services, conduct our associated
6.9 If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on our Apps or our Website, we may collect that information you provide to us. We may process this information as necessary to respond to any social media posts or other public comments you might make, whether they are directed to us or about us, our Websites, mobile Apps or other activities, to resolve disputes, provide customer support and troubleshoot problems, as permitted by law. Lawful Basis: to comply with our legal obligations, performance of our contract with you and necessary for our legitimate interests.
6.10 We may place a cookie on your device when you access our Websites or our Apps. These cookies will let us know when you have accessed our Websites or downloaded or used our App. We will share this information with our advertising providers such as Facebook or Twitter (e.g. IP addresses or unique mobile identifiers). The cookies will let our advertising providers know when to serve ads and to whom, ensuring that our ads are served only to people who have previously visited our Websites or used or downloaded our Apps (“Retargeting”). This is further explained in our Cookies Policy available on our Website here.
10 11 www. alianzafx.com www. alianzafx.com (f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and (g) withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please write to: The Head of Compliance Alianza Fx Limited 68 Hanbury Street E1 5JL [email protected]
10.2 Please quote your name and address. We should be grateful if you would also provide brief details of the data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your data).
10.3 We will require proof of your identity before providing you with details of any personal data we may hold about you. 10.4 We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.
10.5 We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. Alternatively, we may refuse to comply with your request in these circumstances.
11. ACCESS TO A CREDIT REPORT ABOUT YOU 11.1 You have the right to ask for a copy of any credit report we have obtained about you from a credit-reporting agency. However, as we may not have retained a copy after we have used it, the best means of obtaining an up-to-date copy is to get in touch with the credit-reporting agency directly.
11.2 You have a right to have any inaccuracies corrected or, if there is any dispute as to accuracy, to have a note added to your credit reporting agency file explaining your position.
11.3 If we decline your credit application wholly or partly because of adverse information on your credit report, we are required to tell you of that fact.
9.6 Before using or disclosing a government related identifier of an individual, we will ensure that such use or disclosure is: (a) reasonably necessary for us to verify your identity for the purposes of our activities or functions; or (b) reasonably necessary for us to fulfil our obligations to a government agency or authority; or (c) required or authorised by or under a UK law, regulation or a court/tribunal order; or (d) reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body. 10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
10.1 Please note that these rights do not apply in all circumstances. You are entitled to: (a) request access to your personal data (commonly known as a “data subject access request”); (b) request correction of the personal data that we hold about you; (c) request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request; (d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; (e) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; 14.
DATA RETENTION 16.1 We will only retain your personal data for as long as you have consented to it or when is necessary to us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for six years after they cease being customers for tax purposes.
16.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
16.3 In some circumstances you can ask us to delete your data. 16.4 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
17. FURTHER INFORMATION 17.1 If you would like to let us know about something we have done, or failed to do in relation to your personal data, whether positive or negative, please let us know. Your comments enable us as an organisation to learn and continuously improve our services.
17.2 If you think there is a problem with the way we are handling your data, you have the right to complain to the Information Commissioners Office at: https://www.gov.uk/government/
14.2 In the event that our purposes for processing personal data change, we will contact you as soon as practicable and seek your consent where such notification relates to a new additional purpose for processing.
14.3 Remember: Alianza Fx is not responsible for your losses. If you deposit, you automatically agree to put your capital at total risk. Without power after depositing claim nothing. We do not return your money. Since we are not a donation company. We give you the possibility to invest in forex. If you lose, take the risk. If you do not feel able to take the risk of losing the capital, do not deposit.
15. USE OF YOUR PERSONAL DATA SUBMITTED TO OTHER WEBSITES
15.2 If you disclose your personal data to others (e.g. websites we link to), different rules may apply to their use or disclosure of the data that you disclose to them. We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website.
15.3 We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions. 16 17 www. AlianzaFx.com www. AlianzaFx.com 18. YOUR DUTY TO INFORM US OF CHANGES 18.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 18.2 If your personal details change, please help us to keep your information up to date by notifying us at [email protected]
Recuerde: Alianza fx no es responsable por sus perdidas. Si usted deposita, automáticamente está de acuerdo en poner su capital en riesgo total. Sin poder luego de depositado reclamar nada. No devolvemos su dinero. Dado a que no somos una empresa de donación. Le damos la posibilidad de invertir en Forex. Si pierde, asuma el riesgo. Si no se siente capaz para asumir el riesgo de perder el capital, no deposite.
Please note that Alianza Fx Limited’s Head of Compliance deals with data protection-related queries and customer complaints only. For general sales, billing and product support enquiries please contact Alianza Fx’s support team at [email protected]