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
The legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described in this policy, except where we require your consent to use your personal data 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 2007 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 2007 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.
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 optimization of our site.
- Our broker, in the event of any compliance queries;
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
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.
You have the following rights, which can be exercised by contacting us at email@example.com.
- To ask us not to process your personal data for marketing purposes;
- To access personal information held about you and to obtain a copy of it;
- 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 obtain without undue delay the rectification or completion of personal data which are inaccurate or incomplete;
- To restrict or object to the processing of your personal data and to request its erasure under certain circumstances;
- To receive your personal data, which you have provided to SGM-FX, in a structured, commonly-used and machine readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
- 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
- To lodge a complaint about the way in which your personal data is being used to a supervisory authority.
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.
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 firstname.lastname@example.org.
By using the Site, you are providing your consent to SGM-FX storing and using cookies in accordance with this cookies policy. However, you can adjust the settings on the browser you use to view the Site to remove or limit the types of cookies that it accepts. More information about this is set out in the section “Managing Cookies” below.
What are Cookies?
Cookies are small text files that are placed on your computer, mobile or another device that you are using to access a website, so that the website can remember and identify it. They contain anonymous information and will typically include the name of the domain from which the cookie has come; the “lifetime” of the cookie; and a value, usually a randomly generated unique number.
Cookies can be set by the owner of the website itself (“first party cookies“) or by other websites that provide content for the website that you are viewing (“third party cookies“).
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We may also use that information to recognise your computer when you visit our Site, and to personalise our Site for you.
Some cookies used on the Site are temporary and remain on your device until you leave the Site, at which point they are deleted. These are often called session cookies. Session cookies are typically used on the Site to allow you to carry information across pages of the Site and avoid having to re-enter information, and to allow you to access stored information whilst you are logged into a user account on the Site.
Other cookies used on the Site remain on your device once you have left the Site (though how long will depend on the lifetime of the specific cookie). These are often called persistent cookies. Persistent cookies are typically used on the Site to help it recognise your device when you return to it, and to help us improve the structure of the Site by compiling anonymous, aggregated statistics that allow us to understand how users use the Site.
The cookies used by the Site are analytical cookies. These cookies allow us to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are able to find what they are looking for easily, and also to analyse the effectiveness of our marketing campaigns.
Here’s a list of the cookies we use on the Site, and what we use them for. We may, from time to time, update or modify our cookies. If we do, we will update this list.
|Cookie name||Cookie Purpose||When does this cookie expire?|
__utma: This cookie lasts for 2 years by default and distinguishes between users and sessions. It is used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics. The lifespan of the cookie can be customised by website owners.
__utmb: This cookie determines new sessions and visits and expires after 30 minutes. The cookie is updated every time data is sent to Google Analytics. Any activity by a user within the 30 minute life span will count as a single visit, even if the user leaves and then returns to the site. A return after 30 minutes will count as a new visit, but a returning visitor.
__utmc: This cookie is not used in most sites but is set to enable interoperability with the older version of Google Analytics code known as Urchin. In older versions this was used in combination with the __utmb cookie to identify new sessions/visits for returning visitors. When used by Google Analytics this is always a session cookie which is destroyed when the user closes their browser. Where it is seen as a persistent cookie it is therefore likely to be a different technology setting the cookie.
__utmz : This cookie tracks where visitors have come to the Huron site, ie directly browsing to the site, using a search engine (tracks the search term used, etc.), as well as the geographical location of the visitor. It allows Google Analytics to report on how to “credit” a visit or successful ecommerce transaction.
Additionally there is also a cookie called “F5” which comes from the load balancer, to ensure that the visitor’s session is tied to the web server they initially get directed to in the load balancer rotation.
Click here for an overview of privacy at Google:
To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout.
|__utma is a persistent cookie and is deleted 2 years after you leave the Site.
__utmb is a persistent cookie and is deleted 30 minutes after you leave the Site.
__utmc is a session cookie.
__utmz is a persistent cookie and it expires 6 months from the time of creation.
Disabling and Enabling Cookies
Most browsers allow you to refuse to accept cookies. Your browser may have a Help section or some other form of instructions which should explain how to do this. If you are using a smartphone, then the manufacturer should have instructions on its website explaining how to do this (for example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector).
Useful guidelines on how to do this for a number of popular computer browsers can be found at www.ico.org.uk/for_the_public/topic_specific_guides/online/cookies.
Please note that if you do disable any cookies, this will have a negative impact upon the usability of many websites, including this one.