Introduction

Xeroforex treats your privacy rights very seriously. This Privacy Policy sets out how we will deal with your “personal information”, that is, information that could identify, or is related to the identify of, an individual. It should be read with the customer agreement that you enter into with us (“Customer Agreement”).

The personal information we collect

The personal information we hold about you includes:

• Contact details, such as your name, telephone number,  mobile number, date of birth, and address(es),

• Proof of your identity and bank account information,

• Details of services or products you enquire about or get from us, as well as information necessary to respond to

your query or provide you with services or products, including your transactions.

If you choose to pay someone else, for example, add a payment recipient on our website, we will ask you for your recipient’s name, email address, bank account information and physical address. This is necessary for us to make a payment to them and you confirm that you know they agree or that you are otherwise allowed to give us this information.

We get this information from:

• You, for example, when you complete application forms, the way you use our products or services including information from your digital devices (such as checks of the IP address your device connects from) and your dealings with us, including telephone conversations and social media, and

• Third parties, such as people appointed to act on your behalf or credit reference agencies, who may check information against other databases to which they have access.We will make reasonable efforts to tell you if we have collected personal information about you from someone else.

How we use your personal information

We use your personal information:

• To provide our products and services to you,

• For security purposes and to verify your identity,

• For administration, planning and account management,

• To monitor, develop and improve our services and for training and quality purposes, for example, we may record calls,

• To prevent and detect fraud, money laundering and other crime and to comply with the law. This may include checking your location when you use a mobile device to help prevent fraud,

• To tell you about other products and services we offer that may be of relevance to you. We’ll send you messages by email or other digital methods and telephone. These may include messages to manage your dealings with us, or that we are required to send you to comply with our obligations under the Customer Agreement, law or regulation, or marketing messages.

You can opt-out of receiving marketing at any time through the unsubscribe function available in each marketing message we send to you, or you can log into the Xeroforex website and update your preferences or call us on 0203 150 0507

Who we share your personal information with

We may disclose information about you, including your personal information, to the following if you ask us to, it’s required to provide the product or service to you, if we have a duty to disclose it, a law or regulation allow us to do so or for legitimate business reasons:

• Other companies in the Xeroforex includes us, our parent company, Xeroforex, and its other subsidiaries),To our service providers, partners

and agents (including their sub-contractors), including, web hosting, IT systems administrators, mailing houses, debt collectors, and professional advisors,

• Payment processing service providers, intermediaries and financial institutions to process your payments,

• Credit reference agencies, other companies and  organisations to identify you and to protect against fraud,

• Regulators and law enforcement agencies in the UK and in  other countries

• To someone to whom we may or do transfer any business or assets, for example in connection with a restructure, sale or acquisition of any Xeroforex company,

 The personal information that we collect from you may be transferredto, and stored at, a destination outside the European Economic Area

(“EEA”), for example a country where you have instructed us to send a payment. It may also be processed by staff operating outside the EEA who work for us or for one of our service providers and including in countries such as Australia, United States, Canada and Hong Kong. Such staff are likely to be involved in, among other things, processing your transaction or payment details and providing support services. By giving your personal information, you agree to this transfer, storing or processing.

Where we share information with an organisation outside the EEA, we will take all reasonable steps to ensure that they apply equivalent levels of protection as we are required to provide. If this is not possible, for example, we are required by law to disclose your information, we will make sure that sharing the information is lawful.

If we wish to provide your personal information to anyone else, we will identify them and obtain your consent before doing so, unless the provision of that information to that third party is permitted by law.

How long we keep information

We need to keep your information so that we can provide our services to you. Under relevant anti-money laundering and counterterrorism legislation we need to keep your personal information and information about your transactions for at least 5 years from the end of your relationship with us. We may also need to keep it for longer for legitimate business purposes and for other legal and regulatory reasons. Subject to this, we will destroy, erase, or anonymise your personal information when it is no longer needed.

How your information can be updated or corrected

To ensure the information we hold is accurate and up to date, you need to tell us as soon as possible if any of the information you have provided to us has changed, (as required by the Customer Agreement). From time to time, we may also ask you to confirm your details are up to date. We will update our records as soon as possible to ensure we can continue to provide our services to you.

If you want a copy of the personal information we hold about you, you can contact us at enquiries@xeroforex.com. There may be situations where we may not action your request, including where the provision of access would be too costly, the information may contain references to other individuals or for legal, investigative, security or commercial proprietary reasons.

Otherwise we will usually respond within one month of your request and provide you with a copy of your personal information in a commonly used format.

Testimonials you provide

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at enquiries@xeroforex.com.

Tracking technologies

We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

These technologies help us to:

• Provide services to you,

• Allow you to change web pages during your visit without having to re-enter your password,

• Store your preferences and other information and to track activity on our website

• Understand the effectiveness of our promotional campaigns and whether you came to our site from an advertisement or an affiliate website,

• Deliver information specific to your interests on additional  web sites.

A “cookie” is a text file placed on your computer’s hard drive by a web server, which allows for personalisation of certain aspects of your visit to that website. “Web beacons” are transparent electronic images placed in the web code that collect non-personal data while visiting a website. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies may limit the performance of Xeroforex’s websites. If cookies are disabled, certain features of our websites may not function properly, and you may not be able to register or use your online account. There is more information about cookies in our Cookie Policy.

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you don’t wish to have this information used for the purpose of serving you interest-based ads, you may opt-out (click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider

(ISP), referring/exit pages, operating system, date/time stamp, and/ or clickstream data. We do not link this automatically collected data to other information we collect about you.

We use Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please visit: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Social Media Widgets

Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing it.

Links to external websites.

Our website may be linked to or from third party websites. These links are provided as a convenience only. We are not responsible for the content or privacy principles of websites that are linked to or from our website. You should review the privacy policies of any third party websites you visit.

Protecting your information

We have in place a range of security safeguards to protect your personal information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification, regardless of the format in which it is held.

The way we do this depends on the sensitivity of the information and the format in which it is contained. Security measures include technological measures such as Secure Socket Layer (SSL) encryption, which creates a secure connection with your browser when you register and login into our online services, physical measures like restricted access to offices and strategic measures such as security clearances and limiting access to a “need-to-know” basis.You acknowledge that no data transmission over the internet or the telephone can be guaranteed to be perfectly secure.

Any personal information you submit to us or access electronically or over the telephone is done at your own risk. We do not guarantee or warrant the security of information transmitted in these ways. You should also take care not to give any security credentials we provide you or you choose (such as a password) to someone who is not an Xeroforex representative. We will never ask you for your full security credentials. If you are unsure, please end the session or call and call straight away on 0203 150 0507.

A note about children’s privacy

Our website is not directed at children under the age of 18. We will not knowingly collect or maintain personal information on our website from

those we actually know are under the age of 18.

Complaints

If you have a complaint please tell us about it. We take all complaints seriously and investigate all complaints. See our Complaints Policy for more information.

Availability and changes to this Policy

This Policy is available on the Xeroforex website. We may change this Policy from time to time. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact

If you have any queries about this Privacy Policy, need this in an alternative format, or have any complaints about our privacy practices, please contact us at enquiries@xeroforex.com or call us on 0203 150 0507.

Xerororex is registered in England (registered number 12345678) and our registered office is 85 Gracechurch Street, First floor, London EX3V 0AA.We are registered with HMRC as a Money Services Business under the Money Laundering Regulations (reg.