What this Policy is about
RealForexWinner recognises the importance of your privacy and understands your concerns about the security of your personal information. We are committed to ensuring that when you share information with us, or we collect information about those who visit our websites, we do so in accordance with applicable privacy laws.
RealForexWinner Limited (RealForexWinner) is committed to its privacy obligations under the Principles contained in the UK Data Protection Act 1998 and the European Union GDPR (General Data Protection Regulation) which replaced the previous Data Protection Directive 95/46/EC.
RealForexWinner Limited is the Data Controller as defined by the GDPR and they have appointed a Data Protection Officer who can be reached at [email protected], although your initial point of contact should be our Customer Service team, who can be reached at [email protected]
What is Personal Data?
Personal data includes any information or opinion, about an identified living individual or an individual who can be reasonably identified from their information. The information or opinion will still be personal data whether it is true or not and whether it is recorded in a material form or not.
Right to Object
Clients have the right to object to their personal data being used for:
• Direct Marketing.
• Processing based on legitimate interests or the performance of a task in the public interest or in relation to an official authority.
• Processing for statistical purposes.
What kinds of Personal Data do we collect?
When you apply for or maintain an account with RealForexWinner, we collect personal data about you. The personal data we collect about you may include:
• Information you provide to us on applications and other forms, such as your name, address, date of birth, occupation, employer, assets and income, telephone or mobile number, email address and bank account details;
• Information about your transactions with us and with our affiliates;
• Information we receive from other entities not affiliated with RealForexWinner; and Information you provide to us to verify your identity, such as a passport, or information and documents received from other entities not affiliated with RealForexWinner.
Why we collect Personal Data
The products and services we provide usually fall under the scope of our regulated activities and as such we generally have obligations to ask for a range of personal information from you which could include your name, address, date of birth, gender, contact details, occupation, income, assets and liabilities, bank account details, trading history or statements, financial statements, credit reporting information, employment details, location data or any other similar information which could be used to identify you.
We collect, hold, use and disclose personal data for business purposes, such as evaluating your application to open account, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing client service.
We may use your personal data to offer you products and services that we believe may interest you. We will not do this if you tell us not to.
If you do not wish to receive marketing offers from us, please send an email to us at [email protected]
How we collect Personal Data
We obtain most of the information directly from you through application forms or telephone conversations, and from maintaining records of information obtained in the course of ongoing customer service. We may also obtain information from other sources, such as via identity checks.
Sometimes we may ask for other information voluntarily (including through market research, surveys or special offers) so that we can improve our service or better cater to the wider needs of our current and future clients.
We may record communications that we have with you in relation to the services we provide to you and our relationship with you. These recordings may be in electronic format, by telephone, in person or otherwise and will be our sole property, constituting evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or other notice.
If you choose not to provide the information we request, we may not be able to provide you with the product or service you need, or open your trading account.
If you apply to open a trading account (Live or Demo) your application form (whether written or electronic, or in any other form (including verbal) will constitute your express consent to the use and (in certain circumstances) the disclosure of your personal information.
You also consent to the use of your data to carry out an Appropriateness Test when applying for an account so that the suitability of our products to you can be assessed.
How we protect Personal Data
We take our obligations to protect your personal information very seriously and as such we take reasonable steps to hold information securely in electronic or physical form. These steps are supported by a number of security standards, processes and procedures, and we store information in access-controlled premises or in electronic databases requiring logins and passwords.
The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services and any transmission is at your own risk.
To try to prevent this, we use both GeoTrust Secure Socket Layer (SSL) and Transport Layer Security (TLS) encryption technology in order to protect the information that you submit to us. This type of technology is designed to protect you from having your information intercepted by anyone other than RealForexWinner during its transmission. We also use other safeguards such as firewalls, authentication systems (e.g. passwords and personal identification numbers) and access control mechanisms to restrict unauthorised access to systems and data.
Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.
We use a combination of secure computer storage facilities and paper-based files and other records and, irrespective of the format of the information, take steps to protect the personal information we hold from interference, misuse, loss, unauthorised access, modification or unauthorised disclosure.
Some electronic communications through non-secure web platforms may not be secure, virus-free or successfully delivered. If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
You can help us to keep your information secure. Remember that any user name or password in relation to our websites is personal to you and should not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using them.
Who we disclose Personal Data to
We use the information you give us to assess your application, conduct identity checks, verify you and do anything else necessary in order to open your trading account. This includes conducting screening checks in accordance with our obligations under relevant anti money laundering laws and other regulatory laws.
Once this process is complete, the information we hold is used for establishing and managing your account, reviewing your ongoing needs, enhancing our customer service and products and giving you information on any opportunities that we believe may be relevant to you.
We may also use your personal information for the future planning of our business, including product development and research. In such instances (and in instances where we have legal or regulatory obligations), and depending upon particular restrictions on sensitive information, you consent to the disclosure of your personal information where we disclose that information to:
- Relevant regulators or government authority as required, authorised, permitted or
compelled by law;
- Other companies within the RealForexWinner group (including our associated companies
elsewhere in the world) who may be involved in administering your account or providing
other services for the RealForexWinner group;
- Where applicable, anyone authorised by you (for example, your financial adviser);
- An introducing broker, referrer, or third-party broker or agent who may have introduced
or referred you to us (this is necessary in order to pay fees or commissions for such a
referral and can include any click-through links you may have clicked on); and
- Third party service providers, including those who help facilitate or support our business,
or develop new software to run our business more efficiently (these could include specialist
advisers who have been contracted to provide us with administrative, IT, financial,
regulatory, compliance, taxation, insurance, research or other services).
Where we share your personal data in the ways set out above, you acknowledge and
understand that this may result in your personal data being sent outside Europe. Where
this occurs, while we make reasonable attempts to, you acknowledge that we may not be
able to extract an undertaking from the overseas recipients that they will comply with
European Privacy laws and the ability to enforce European Privacy laws or any other
contractual privacy obligation in relation to any breach may be very limited. As such, we will
not be accountable for any breaches of those laws by that overseas recipient.
Because the European Privacy laws may not apply or be enforceable against some
overseas recipients we understand that you may choose not to disclose your personal
information to us. If you choose not to provide the information however, we may not be able
to open your trading account, or provide you with the product or service you have requested.
Sharing information with our Affiliates
We may share personal data described above with our affiliates for business purposes, such as servicing client accounts and informing clients about new products and services, as permitted by applicable law. Our affiliates are companies controlled or owned by us, or companies controlling or under common control with us, and include financial service companies, such as dealers, other brokers, futures commission merchants and advisors.
Disclosure to Non-Affiliated Third Parties and Regulatory Bodies
In order to support the financial products and services we provide to you, we may share the personal data described above with third-party service providers and joint marketers not affiliated with us, including:
• Financial service institutions (advisors, dealers, brokers, trust companies and banks) with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor; and
• Companies under contract to perform services for us or on our behalf, such as service providers that prepare statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.
These companies acting on our behalf are required to keep your personal data confidential.
We may also be required to provide your personal data to law enforcement agencies and other regulatory and government bodies from time to time in the UK and overseas.
RealForexWinner collects the information from you electronically when you visit our websites, including date and time of visit, number of pages viewed, how you navigate through our Websites.
Cookies are small files containing information that a website uses to track its visitors.
RealForexWinner may set and access RealForexWinner cookies on your computer, enabling us to learn which advertisements and promotions bring users to our website. RealForexWinner or any of its affiliates or divisions may use such cookies.
You can choose whether to accept Cookies or not on your computer.
Accessing and updating your Personal Data
You have the right to request a copy of the personal data about you which we hold in order to correct any inaccuracies and to object to our using your personal data for a marketing purpose, and this is known as a Subject Access Request.
To do this, you should contact us using the details set out below in the “Contact Us” section. There is no fee for requesting that your personal information is corrected, however in processing your request, our reasonable costs may be recovered if necessary if the relevant legislation allows. This covers such things as locating the information and supplying it to you.
Where we refuse to action your request to correct your personal information, you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
Known as the ‘right to be forgotten’ you may request that we delete all personal data about you which we hold, although we are limited by the law with regards to who this applies.
The conditions for erasure, as outlined in article 17 of GDPR, include the data no longer being relevant to original purposes for processing, or clients withdrawing consent.
GDPR introduces data portability, which is the right for a client to receive the personal data concerning them, which they have previously provided, in a ‘commonly used and machine readable format’ and have the right to transmit that data to another data controller. This means that if requested by a client RealForexWinner will put all their data onto a CSV file and if requested to send that file to another company.
With the introduction of the GDPR you have additional rights with regard to your Personal Data. Some of these may not be applicable to you due to additional regulatory obligations placed upon us which we are required to meet for all Live accounts that have been opened.
• Right to be informed
• Access to your Personal Data
You have the right to request a copy of the personal information that we hold about you, and if you wish to exercise that right please contact [email protected]
• Correction of Personal Data
You can make a request for us to correct any personal data that we are processing about you which is incorrect.
• Right of erasure
You can request that we erase your personal data if there is no reason for us to continue using it.
• Right to data portability
This right allows you to obtain a copy of your Personal Data which we hold in a format that will enable you or us to transfer it to another organisation. Multiple requests of this type may incur a fee to cover reasonable expenses.
• Right to restrict processing of personal data
You have the right in certain circumstances to request that we suspend our processing of your personal data. For example, you have the right to opt out of Marketing emails. Where we suspend our processing of your Personal Data we will still be permitted to store your Personal Data, but any other processing of this information will require your consent, subject to certain exemptions.
• Right to object to processing of Personal Data
You have the right to object to our use of your Personal Data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
• Rights relating to automated decision making and profiling
You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process.
If you believe that a breach of your privacy has occurred or are concerned about how your personal data is being handled, please contact us using the details below:
100 Old Broad St
London. EC3A 1AT
Email: [email protected]
Phone: 0800 612 8484 or +44(0)203 655 7564