This policy (together with FCD’s [terms and conditions] and any other documents referred to in it) sets out the basis on which any personal data FCD collects from you, or that you provide to FCD, will be processed by FCD. Please read the following carefully to understand FCD’s views and practices regarding your personal data and how FCD will treat it. By visiting www.currencies.co.uk (‘the website’), by registering with the website, and / or by placing orders with FCD you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the ‘Act’), the data controller is Foreign Currency Direct Plc (company number 05082565) having its registered office at Currencies Mews, Badminton Court, Old Amersham, Buckinghamshire, HP7 0DD.
FCD will collect and process the following data about you:
1.1 Information you provide FCD. This is information about you that you provide to FCD by filling in forms on the website, or by corresponding with FCD by phone, email or otherwise. It includes information you provide when you register to use the website, subscribe to FCD’s service, search for a product, place an order with FCD for its services, update any information you hold with FCD, report a problem with the website and / or have a discussion with FCD staff. The information you give FCD may include:
(a) If the client is an individual: your personal details including, without limitation, full name, address, time lived at that address, date of birth, telephone number(s), email address, bank details, nationality, country and place of birth, tax residency, financial status and condition, source of wealth, employment and business activities, the source or destination of funds and the reason(s) for carrying out the currency exchange transactions and money transfers; and
(b) If the client is not an individual: (i) any person whom the client authorises or nominates to instruct FCD and enter into binding contracts with FCD for the purposes of currency exchange transactions and money transfers (an ‘Authorised Person’), (ii) with respect to Authorised Persons or other relevant individuals connected with the client (including, without limitation, directors or relevant employees and beneficial owners), the information set out above at paragraph (1.1(a)) with respect to such individuals, and (ii) the source or destination of funds and the reason(s) for carrying out currency exchange transactions and money transfers.
You may also provide FCD information about a third party, if the destination account is in the name of that party. That information may include that third party’s name and bank details and the details set out at paragraph 1.1(a) above. It is your responsibility to ensure that this information is accurate and that you have the authority to provide this information about those persons.
1.2 Continuing Accuracy: FCD will require you to confirm the accuracy of the information which you provide FCD and, where necessary, require you to update it. When your details change (for example, because you have changed name or address) we require you to update us and, where necessary, provide us with the relevant documentation.
1.3 Information FCD collects about you. With regard to any contact you may have with FCD or to each of your visits to the site, FCD will automatically collect the following information:
(a) electronic messages, recordings or transcripts of recordings of telephone conversations made between FCD and the client or Authorised Person;
(b) technical information, including, without limitation, the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
(c) information about your visit, including, without limitation, the full Uniform Resource Locators (URL), clickstream to, through and from the site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call FCD’s customer service number.
1.4 Information FCD receives from other sources. This is information FCD receives about you if you use any of the other websites FCD operates or the other services FCD provides. In this case FCD will have informed you when it collected that data if FCD intends to share that data internally and combine it with data collected on the site. FCD will also have informed you for what purpose it will share and combine your data.
As part of the Service, FCD will carry out certain Customer Due Diligence checks with third parties (including conducting sanctions screening, identity checks and conducting searches with credit reference agencies) about you, Authorised Persons or other relevant individuals connected with the client (including, without limitation, directors or relevant employees and beneficial owners). FCD may find out additional information about you, Authorised Persons or other relevant individuals connected with the client (including, without limitation, directors or relevant employees and beneficial owners), as a result of those checks. Where legally permitted to do so, FCD will inform you when it collected that data if FCD intends to share that data internally and combine it with data collected on the site. FCD may also use this information to carry out anti-fraud measures and checks before and during the course of your relationship with FCD;
1.5 FCD works closely with third parties (for example, introducers and credit reference agencies). They may provide to FCD the following information: name, address, telephone number, address of the relevant property you wish to purchase, the country you intend to move to, the progress or status of the transaction, a copy of your passport, a copy of the sale or purchase agreement, and any other information or documentation that is relevant to the transaction. FCD will endeavour to notify you when it receives information about you / Authorised Persons from those third parties and the purposes for which FCD intends to use that information.
As FCD receives (from the client and third parties) information about Authorised Persons and any other person FCD might reasonably be required to contact in connection with the services it provides, it is the responsibility of the client or Authorised Persons to ensure that this information is accurate and that the client or third party has the authority to give this information about those persons.
2.1 A cookie is a small file of letters and numbers that FCD stores on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
2.3 FCD uses the following cookies:
(a) Strictly necessary cookies. These are required for the operation of the site. They include, for example, cookies that enable you to log in to secure areas of the site (if applicable).
(b) Analytical/performance cookies. These allow FCD to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps FCD to improve the way the site works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These recognise you when you return to the site. This enables FCD to personalise content for you and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These record your visit to the site, the pages you have visited and the links you have followed. FCD will use this information to make the site and the advertising displayed on it more relevant to your interests. FCD may also share this information with third parties for this purpose.
2.5 You can block cookies by activating the setting on your browser that allows you to refuse the settings of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the site. If you would like more information about cookies, FCD can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.
FCD uses information held about you in the following ways:
3.1 Information you provide to FCD. FCD will use this information:
(a) to carry out its obligations arising from any contracts entered into between you and FCD and to provide you with the information, products and services that you request from FCD. This may include, but shall not be limited to, the following specific acts;
(i) to carry out relevant checks for the purposes of your registration with the site. This may involve FCD transferring the information to a third party information provider (for example, an identity reference agency);
(ii) to contact you (using the email, fax or telephone details provided) if additional Margin is required to perform the service (please see clause 31 of the terms and conditions for more details);
(iii) to carry out anti-fraud measures and checks before and during the course of your relationship with FCD;
(iv) to carry out Customer Due Diligence (‘CDD’) checks about you, Authorised Persons or other relevant individuals connected with the client (including, without limitation, directors or relevant employees and beneficial owners), for example conducting sanctions screening, identity checks and conducting searches with credit reference agencies;
(v) to contact the bank of the account notified to you by FCD into which any payments are to be made, to check that the payment has been received before proceeding with any payments as part of the services;
(vi) to provide you with information about other goods and services FCD offers that are similar to those that you have already purchased or enquired about;
(vii) to provide you, or permit selected third parties to provide you, with information about goods or services FCD or that third party feels may interest you;
(A) if you are an existing customer, FCD or a third party on FCD’s behalf will only contact you by electronic means (email or SMS) or by letter with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you; and
(B) if you are a new customer, and where FCD permits selected third parties to use your data, FCD (or they) will contact you by electronic means or by letter only if you have consented to this.
If you do not want FCD to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which FCD collects your data (the registration form). If you are an existing customer, you can notify your Account Manager by email if you no longer want FCD to use your data in this way, or to pass your details on to third parties for marketing purposes. You should allow ten (10) working days to be removed from the marketing lists.
(b) to notify you about changes to FCD’s service; and
(c) to ensure that content from the site is presented in the most effective manner for you and for your computer.
3.2 Information FCD collects about you. FCD will use this information:
(a) to administer the site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) to refer to messages or recordings or transcripts of telephone conversations FCD may have had with you to resolve any dispute FCD may have with you;
(c) to improve the site to ensure that content is presented in the most effective manner for you and for your computer;
(d) to allow you to participate in interactive features of the service, when you choose to do so;
(e) as part of FCD’s efforts to keep the site safe and secure;
(f) to measure or understand the effectiveness of advertising FCD serves to you and others, and to deliver relevant advertising to you;
(g) to make suggestions and recommendations to you and other users of the site about goods or services that may interest you or them;
(h) to carry out anti-fraud measures and checks before and during the course of your relationship with FCD; and
(i) to carry out Customer Due Diligence (‘CDD’) checks about you, Authorised Persons or other relevant individuals connected with the client (including, without limitation, directors or relevant employees and beneficial owners), for example conducting sanctions screening, identity checks and conducting searches with credit reference agencies.
3.3 Information FCD receives from other sources. FCD will combine this information with information you provide and information FCD collects about you. FCD will use this information and the combined information for the purposes set out above (depending on the types of information FCD receives).
4.1 You agree that FCD has the right to share your personal information with:
(a) any member of its group, which means its subsidiaries, its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; and
(b) selected third parties including:
(i) introducers, affiliates and other business partners, suppliers and sub-contractors for the performance of any contract FCD enters into with them or you (including third parties who provide customer review and feedback services and email marketing service providers). Any third party email marketing service providers will only contact you about services of FCD that we think may be of interest to you;
(ii) FCD’s affiliates with certain key information about you or the status of the transaction;
(iii) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. FCD does not disclose information about identifiable individuals to its advertisers, but it will provide them with aggregate information about its users (for example, FCD may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). FCD may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). FCD may make use of the personal data it has collected from you to enable it to comply with its advertisers wishes by displaying their advertisement to that target audience;
(iv) analytics and search engine providers that assist FCD in the improvement and optimisation of its site; and
(v) sanctions screening, identity and credit reference agencies for the purpose of performing our CDD obligations and assessing your credit score where this is a condition of FCD entering into a contract with you.
4.2 FCD will disclose your personal information to third parties:
(a) in the event that FCD sells or buys any business or assets, in which case it will disclose your personal data to the prospective seller or buyer of such business or assets;
(b) if FCD, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
(c) if FCD is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the [terms and conditions] and other agreements; or to protect the rights, property, or safety of FCD, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.2 All information you provide to FCD is stored on secure servers. Where FCD has given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. FCD asks you not to share your password with anyone.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although FCD will do its best to protect your personal data, it cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once it has received your information, FCD will use strict procedures and security features to try to prevent unauthorised access.
6.1 You have the right to ask FCD not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms FCD uses to collect your data. You can also exercise the right at any time by contacting your Account Manager by email.
6.2 The site may, from time to time, contain links to and from the websites of FCD’s partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that FCD does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet FCD’s costs in providing you with details of the information FCD holds about you.