SGM-FX Limited (“SGM-FX”) (also “we” and “us”) is committed to respecting and protecting your privacy.
This policy explains the basis on which any personal data we collect from you, or that you provide to us, will be used, the control you have over your personal data and the procedures we have in place to protect it. It applies to any personal data which is collected and/or provided through (i) our SGM-FX websites, namely https://www.sgm-fx.com/ (the “Websites”) and (ii) orders placed with SGM-FX via telephone or email.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By visiting our Websites or placing an order via e-mail or telephone you are accepting the practices described in this policy. We take responsibility for the personal data we collect about you, and we aim to be transparent about how we handle it, and give you control over it.
Information We Collect From You
We will collect and process the following data about you:
- Information you give us: This is the information that you give us by filling in forms on our Websites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Websites, subscribe to our service or newsletters, search or interact with our Websites and when you report a problem with our Websites. The information you give us, may include your name, address, email address and phone number, the nature of the product or service you are interested in, transaction details, any details required to verify your identity (which may include photo ID such as a passport or driving licence) and your login and password to allow us to access the platform on your behalf.
- Information we collect about you: We will monitor or record any telephone conversations between you and our staff.
We use information in the ways set out below
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing your data are:
- We have a legitimate interest
- We have a contractual obligation
- We have a legal obligation
- Your consent for a specific purpose, as identified below.
Information you give to us
We will use this information:
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products and services that you request from us, including newsletters or email notifications that you have requested;
- To carry out checks on you, such as credit checks, identification verification checks and anti-money laundering checks, for the purposes of meeting our obligations under the Money Laundering Regulations 2017 and any other applicable legislation, crime prevention, fraud prevention and credit risk reduction;
- To enable you to participate in the interactive features of the site;
- To deal with any queries, complaints or problems reported on the site;
- To notify you about changes to our service; and
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
We do not carry out any automated processing using your personal data.
Information we collect about you
We will use recordings of telephone conversations with our staff for authentication, security, dispute resolution, quality and training purposes only.
Information we receive from other sources
We will not combine the information you give to us and the information we collect about you with information received from other sources, other than:
- Information received from a third party where there is a signed power of attorney in place; and
- Information received from a third party who is providing funds to you for the purpose of a transaction with us.
We will only use this information for the purposes set out above and to carry out checks on the third parties for crime and fraud prevention purposes.
In most cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. If you have ordered a service from us, it will be a statutory requirement for us to obtain, and a contractual requirement for you to provide, certain information so that we can verify your identity in order for us to meet our obligations under the Money Laundering Regulations 2017 and any other applicable legislation, for the purposes of crime prevention, fraud prevention and credit risk reduction. You are obliged to provide this information in order for us to provide the service and if you fail to provide it, we will be unable to provide the service.
Your information is securely stored on designated drives and servers and shall only be uploaded to an approved cloud computing service. Servers containing Personal Data shall be sited in a secure location, away from general office space. All servers and computers containing Personal Data shall be protected by approved security software and a firewall.
When no longer required, we will dispose of your information by deleting files from our data storage, and any Personal Data printouts, shall be shredded and destroyed securely.
Disclosure of your information
You acknowledge that we have the right to share your personal data with the following recipients to the extent permitted by applicable data protection law:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
- Selected third parties, including:
- Our broker, in the event of any compliance queries;
- The third parties which we use to carry out the checks that we need to carry out on you, such as identification verification and anti-money laundering checks; and
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- If SGM-FX (or one of its subsidiaries) 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; and
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property or safety of SGM-FX, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
International Data Transfers
The UK government has stated that transfers of data from the UK to the EEA are permitted. This will be kept under review. Your personal data will not be transferred, or stored, outside of the European Economic Area (“EEA”) without your prior written consent.
We maintain appropriate administrative, technical and physical safeguards to protect your personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction.
SGM-FX will be the data controller of your personal data. We have appointed Julie Neal, 41 Eastcheap, London, EC3M 1DT as our Company Data Protection Officer. You can contact our Company Data Protection Officer on +44 207 220 1740 or firstname.lastname@example.org if you wish to make a request.
Under data protection law, you have the rights including :
- Your right of access – you have the right to ask us for copies of your personal information.
- Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – you have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- To ask us not to process your personal data for marketing purposes;
- To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
- To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Changes to this Privacy Statement
If you have any questions, comments or concerns about any aspect of this policy or how SGM-FX handles your information please contact us at email@example.com.
How to Complain
If you have any concerns about our use of your personal information, you can make a complaint to us at firstname.lastname@example.org.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk