Privacy Policy

(Last updated April 16th, 2020)

 

  1. Acceptance And Use

 

This privacy policy covers Alkaline FX LTD and its subsidiaries including (collectively, "Alkalinefx," "we" "us" or "our"). We provide the website and related services through our sites, including www.Alkalinefx.com. Your privacy is importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of our users. This Privacy Notice sets out how Alkalinefx products and services provided in United Kingdom by Alkaline FX LTD; 

 

“We”, “Us”, and the trading and direct sales services provided by Alkalinefx (collectively the “Alkalinefx” or “services”), collects, uses and manages the personal information we receive from you, or a third party, in connection with our provision of services to you or which we collect from your use of our services and/or our website. The Privacy Notice also informs you of your rights with respect to the processing of your personal information.

 

  1. Acceptance and Use

  2. Data Protection Principles

  3. Data We Collect About You

  4. Personal Information

  5. Non-Personal Information

  6. Payment Processing And Payment Processor

  7. How Alkalinefx Collects Your Information

  8. Registration 

  9. Information Collected Through Technology

  10. Other Information You May Submit

  11. Automatically-Collected Information

  12. How We Use Your Data

  13. Remarketing On The Website And Platform

  14. Google Adwords

  15. With Whom We Share Your Data

  16. Data Retention

  17. Your Privacy Choices

  18. Security Measures For Safeguarding Your Information

  19. Third-Party Website And Links

  20. Emails Communications

  21. Mobile Device Communications

  22. Data Security

  23. GDPR Statement for (EEA Users)

  24. Transfers of personal information outside of the (EEA) and the United Kingdom (UK)

  25. Transfers of Personal Information outside of your country

  26. Privacy when using digital assets and blockchains

  27. California Residents Consumer Act CCPA

  28. California Resident Rights (CCPA)

  29. Privacy Complaints Procedure

  30. Changes to Alkalinefx’s Privacy Policy

  31. Contact Us

 

 

  1. Data Protection Principles

 

“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.

 

We are committed to complying with applicable data protection laws and will ensure that personal data is:

 

  • Used lawfully, fairly and in a transparent way;

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

  • Relevant to the purposes we have told you about and limited only to those purposes;

  • Accurate and kept up to date;

  • Kept only as long as necessary for the purposes we have told you about;

  • Kept securely.

 

  1. Data We Collect About You

 

Alkalinefx may collect two (2) types of information about you: personal and non-personal.

 

  1. Personal Information

 

Personal information refers to information that lets Alkalinefx know the specifics of who you are and which may be used to identify, contact or locate you (e.g. when you provide us with your personal details, such as your name and email address. 

 

The information you give us may include your name, address, e-mail address, phone number, financial information (including Bank account information, credit card details), and geographical location. Alkalinefx may also collect personal information when you use the Alkalinefx materials including, without limitation, setting up account information, filling out surveys, corresponding with Alkalinefx, or otherwise volunteering information about yourself.

 

We also collect Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;

 

  1. Non-Personal Information

 

Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or website visitations). Alkalinefx may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.

 

  1. Payment Processing And Payment Processor

 

Payments made on the Alkaline FX LTD website and platform are not collected by us but through our designated payment gateway provider (PayPal). You will be providing credit or debit card information directly to them who operate a secure server to process payment details, encrypting your credit/debit card information, and authorizing recurring payment. The information which you supply to our payment provider is not within our control and is subject to their privacy policy and terms and conditions.

 

Note your payment card details are not shared with Alkaline FX LTD by the provider

 

  1. How we Collects Your Information

 

The personal information practices set forth platformly to all Alkalinefx’s customers worldwide.

 

  1. Registration

 

Prior to using one or more of the Alkalinefx materials, Alkalinefx may require certain personal information and non-personal information to create an individual account (“account”) or to enable features or functionality of the Alkalinefx materials. Failure to provide all required information required by Alkalinefx may prevent access to any or all Alkalinefx materials, and failure to maintain accurate information may result in suspension or termination of access to any or all Alkalinefx materials.

 

We may also need additional commercial and/or identification information from you e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.

 

  1. Information Collected Through Technology

 

While you are able to visit the Alkalinefx site and remain anonymous, Alkalinefx or its third party service providers may still collect non-personal information about your use of the Alkalinefx materials (e.g. Your internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:

 

  1. Cookies. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer’s hard drive which work by assigning to your computer a unique number that has no meaning outside of the Alkalinefx site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the Alkalinefx materials unavailable to you.

  2. IP address. You may visit many areas of the Alkalinefx site anonymously without the need to become a registered user. Even in such cases, Alkalinefx may collect ip addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Alkalinefx site and each time you request one of Alkalinefx’s pages, the server logs your ip address.

  3. Beacons. Beacons are small pieces of data that are embedded in web pages and e-mails. Alkalinefx may use these technical methods in html e-mails that Alkalinefx sends to users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that constitutes personal information.

  4. Tracking content usage. If you use the Alkalinefx services and you post audio visual materials including, without limitation, text, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “content”) to your website or to a third party website, Alkalinefx tracks and captures non-personal information associated with user accounts and the use of content.

 

  1. Other Information You May Submit

 

You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.

 

  1. Automatically-Collected Information

 

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, and basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our cookie policy.

 

  1. How We Use Your Data

 

We may use your data for the following purposes:

 

  • Identification and authentication: we use your data to verify you when you access your account.

  • Performance of a contract: We process personal data in order to provide our services to you, as well as information regarding our services based on the contractual relationship with our clients (i.e. so as to perform our contractual obligations). The use of your personal information is necessary for us to know who you are, as we have a legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations

  • Communicating with you: we use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).

  • Improving our services: we use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).

  • Customizing your experience: we use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying platform that you might enjoy, based upon your viewing choices.

  • Marketing and advertising: we use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. This may include "targeted ads" based upon your activities.

  • Exercising our rights: where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our terms of service.

  • Legal compliance: we use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.

  • Protecting your information: where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above.

 

  1. Remarketing On The Website And Platform

 

If you have provided your consent by accepting Targeting Cookies on the Website or enabled Targeting on the Platform, we may use Google AdWords (remarketing and Similar Audience features) and Facebook Ads. You can review the Alkalinefx cookie policy which includes details on how to customize your cookie settings.

 

  1. Google Adwords

 

Google AdWords enables Google, through the use of cookies, to identify the fact that you have visited the Website / Platform, to identify aspects of your usage of the Website / Platform and combine that with what it knows about your usage of other websites in the Google ad network.

 

We use these services to advertise to visitors of Google ad network websites who have previously visited our Website / Platform or who Google deems to have shared interests with visitors of our Website / Platform. Google’s collection and use of your personal data is covered by the Google privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page.

 

  1. With Whom We Share Your Data

 

We share data with third parties as follows:

 

  • With your consent: we may share your data with third parties where we have obtained your express consent to do so. You may revoke these consents.

  • Authorized vendors: we may share your data with third-party vendors that help us operate our services, process payments, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (cdns), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (crm) vendors

  • Advertising: we may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, email address, or physical address with such persons.

  • Analytics: we may share your data with persons who provide analytics showing how customers are using our services.

  • Affiliates and advisors: we may share your data with our affiliates company, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with our parent or any affiliate for other purposes, such as direct marketing.

  • Certain legal situations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction.

  • Aggregated or anonymized information: we may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.

 

  1. Data Retention

 

We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

 

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

 

  1. Your Privacy Choices

 

We enable you to make numerous choices about your data:

 

  • You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.

  • You may change your account and video privacy settings. You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.

  • You may opt out of receiving commercial emails from us.

  • You may limit the use of cookies. See our cookie policy for options.

  • You may backup your platform.

  • You may close your account (which will delete all platform) or delete certain platform.

  • Users from certain countries may have additional rights.

 

  1. Security Measures for Safeguarding Your Information

 

Alkalinefx takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Alkalinefx’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Alkalinefx stores personal information. All Alkalinefx employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of personal information.

 

  1. Third-Party Website And Links

 

The Alkalinefx contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Alkalinefx may use third parties to provide components of the Alkalinefx contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Alkalinefx. Alkalinefx: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such websites; and (c) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them

 

  1. Emails Communications

 

By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

 

  1. Mobile Device Communications

 

We may, with your consent, send push notifications in our platforms. You may disable these by declining them or changing the platform's settings. To the extent provided, we may, with your consent, send SMS messages to your mobile telephone for authentication and security purposes. You may opt out of receiving such messages at any time

 

  1. Data Security

 

We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available.

 

Our data centers and those of our partners utilize modern physical security measures to prevent unauthorized access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.

 

All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.

 

The Website or Platform may offer chat rooms, forums, message boards, or news groups to users. It is important to remember that any information disclosed in these areas becomes public information. Accordingly, as with any public forum, you should exercise extreme caution when deciding whether to disclose your personal information.

 

  1. GDPR Statement for (EEA Users)

 

This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Alkalinefx's policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United Kingdom (or other countries) based upon the following legal frameworks:

 

  • Legitimate business interests: we could not provide our services or comply with our obligations to you without transferring your personal information to United Kingdom

  • Consent: we may transfer your personal information when we receive your express, revocable consent.

  • Our use of standard contractual clauses (also known as "model clauses") where appropriate.

  • You have the right to: opt out of non-essential cookies (see our cookie policy); access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. 

 

We enable exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users to change their information, download platform, and close their accounts. We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

 

If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

 

  1. Transfers of personal information outside of the (EEA) and the United Kingdom (UK)

 

We may transfer your personal information outside the EEA and UK to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of the EEA and UK, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the European Union (EU) General Data Protection Act 2016 and the UK Data Protection Act 2018. If transfers of personal information are processed in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules, and EU-US Privacy Shield.

 

  1. Transfers of Personal Information outside of your country

 

By using our products and services, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country. In all such transfers, we will protect your personal information as described in this Privacy Notice, and ensure that appropriate information sharing contractual agreements are in place. Transfers of personal information from APAC countries will be in line with the APEC Framework.

 

  1. California Residents Consumer Act CCPA

 

California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: contact@alkalinefx.com

 

If you are a resident of the European Economic Area, please see the section below headed “Additional Information for users in the European Economic Area” for further information about your privacy rights.

 

  1. California Resident Rights (CCPA)

 

If you are a California resident who has provided us with your Personal Information during the creation of or during the course of establishing a relationship that is primarily for personal, family, or household purposes, you may, once per calendar year, request information regarding our disclosure of certain categories of your Personal Information. Specifically, pursuant to California Civil Code 1798.83 (the “Shine the Light” law), we will provide you a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. You must submit your request to us either by our e-mail address 

 

  1. Privacy Complaints Procedure

 

Where you believe that we have not complied with our obligations under this Privacy Notice, or the applicable law, you may have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have and Alkalinefx will respond in line with our complaints procedure – our contact details are set out in the contact us section below.

 

We want to deal with your concerns fairly, effectively and promptly. However, some complaints are more complex than others and may take some time to investigate.

 

  • We will acknowledge your complaint promptly after receiving it

  • We will keep you informed throughout any investigation

 

In order to assist in the speedy resolution of any complaint you may have, it’s important that we understand your complaint fully. Sometimes this means we may ask you to address your concerns to us in writing. This can be either by email or post to the addresses. We have established internal procedures for investigating any complaint, which may also involve experienced members of staff from Alkalinefx Companies considering or investigation the complaint. Where appropriate, the complaint will be dealt with by someone who was not directly involved in the matter which is the subject of your complaint. The member of staff will either have authority to settle your complaint or will have ready access to someone who has the authority. Our response will fully address the subject matter of your complaint and, if appropriate, will offer redress. If you phone us during our investigation and the member of staff handling your complaint is not available, then another member of our team will try to assist you.

 

Unless applicable data protection laws require responses within shorter timescales, we will try to resolve any privacy complaints you have within 15 business days of receiving your complaint and in exceptional circumstances, within 35 business days (and we will let you know if this is the case).

 

As noted above, if you are not satisfied with our reply/outcome, or otherwise with the handling of the complaint, you may have the right to lodge a claim before a relevant Data Protection Authority or the courts.

 

  1. Changes to Alkalinefx’s Privacy Policy

 

Alkalinefx continually strives to implement new technologies and processes to better protect you, your privacy and your use of the Alkalinefx service. As a result, changes to this privacy policy may be made by Alkalinefx from time to time. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure, as such measures are described in this privacy policy.

 

  1. Contact Us

 

If you have any questions about this privacy policy please contact us at contact@alkalinefx.com

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Any opinions, chats, messages, news, research, analyses, prices, or other information contained on this Website are provided as general market information for educational and entertainment purposes only, and do not constitute investment advice. The Website should not be relied upon as a substitute for extensive independent market research before making your actual trading decisions. Opinions, market data, recommendations or any other content is subject to change at any time without notice. ALKALINE FX LTD, will not accept liability for any loss or damage, including without limitation any loss of profit, which may arise directly or indirectly from use of or reliance on such information.

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