• To respect the confidentiality of personal information
• To protect individuals’ right to privacy
• To maintain confidence and trust in the way we handle personal data by introducing technical and organisational measures in order to protect the security and the confidentiality of the personal data we collect and process.

This Privacy Policy explains how and why we collect, manage, retain and share personal data about you and what measures we take to comply with the Legislation and to keep personal data secure for the period required.

Personal Data we collect includes:

• Name
• Date of Birth
• Email address
• Postal address
• Information on employment status and income
• Nationality
• National insurance number
• Postal address
• Information on employment status and income
• Nationality
• National insurance number
• Driving licence (copy of Passport, tax number for residents of certain countries)
• Bank account details
• Telephone number
• IP address

To confirm the above information, we ask you for proof of permanent address, including a utility bill, a copy of the passport or a driving licence. We also collect and store client reports such as trading history and deposit history, and communication between GKFX and the client, including emails and telephone calls, for regulatory purposes.
For employees, we collect references, previous employment history, Curriculum Vitae, academic records, bank account details.

Why We Collect Personal Data

We collect, process and manage your personal data in order to perform our services, rights and obligations set by contract with you; to comply with our legal obligations; to exercise our legitimate interests or upon your consent. Please see below the purposes that we may process your personal data for:

• To determine if you are appropriate for our services and products
• To confirm your identity and to maintain your personal profile
• To update your profile on your notification;
• To manage your account and to provide you with account support, including updates, notifications, and matters concerning your trading activities and the activities of GKFX;
• To provide you with information about your account;
• To provide the products and services for which you signed up;
• To comply with the requirements of the FCA, other Regulators and applicable law;
• To settle enquires, defend legal claims and support regulatory requests
• To contact you when necessary or appropriate in relation to services provided to you;
• To keep you updated whilst you are a client in relation to matters such as your trading activities;
• To detect and prevent fraud, unlawful activity and security issues;
• To provide you with access to our payments services for fund management;
• To manage and administer the products and services provided to you;
• To provide you with information regarding the products and services offered by GKFX;
• To assist you in developing an understanding of the products and services that you may be interested in obtaining from GKFX;
• To improve our services and the client experience;
• To provide you with information or opportunities that we believe may be relevant to you;
• To create anonymised statistical data;
• To provide you with security alerts;
• To form profiles in relation to your characteristics, preferences and interactions so that we can make automated decisions in relation to our services, marketing and advertisements;
• To analyse your activity for business reporting activities.

Consent

Where your consent is required for processing of your personal data, we always request it before we obtain and process your personal data and we inform you as to the purpose of the processing. You can withdraw your consent at any time. In cases where we might have shared your data with third parties, we will also notify those parties of your decision to withdraw your consent

How We Collect Personal Data

GKFX collects and processes personal data from our own website and applications we own, run and manage directly, such as the GKFX registration form on our website, from the client MT4 account and from webinars and newsletters for which individuals sign up from time to time. GKFX also collects personal data via third parties with whom we do business, such as Introducing Brokers or via third parties’ websites through which individuals sign up for GKFX products.
When we collect personal data via third parties, we ensure that these parties have asked for your consent before they share your data with us. Subsequently, we always identify ourselves in our first communication to you and the state the purpose for which we require the data.
Also, for regulatory purposes, we reserve the right to obtain information on you from other sources such as credit reference agencies or fraud prevention agencies.

How Long We Keep Personal Data For (Retention Of Data)

• Clients - we are obliged by the FCA to keep records of our clients for a 5-year term post termination/closure of account, unless we need to retain such data for a longer period (legitimate interest, legal obligation).
• Prospective clients (leads) – currently the company retains data for a maximum term of 2 years post application, provided the prospective client has remained inactive, unless the prospective client expressly requests deletion of their data from our database.
• For prospective employees - currently GKFX retains data for 1-year post rejection of the application for a position, unless the prospective employee expressly requests deletion of their data from our database.

We have introduced appropriate technical measures to destroy or to erase from our systems all personal data which is no longer required.
Where you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not wish to receive communication related to our marketing activities.

Your Rights

GKFX is required by Legislation to respond to any personal data request within 30 days, unless the type of request requires more time for investigation and assessment. The privacy rights which are applicable in our industry are the following:

• You have access right; This means that you may request for a copy of your personal information that GKFX holds. The initial request is free of charge; however, depending on volume and complexity of the matter, we may charge a reasonable administrative fee for subsequent requests.
• You have a right to update your profile, so that the personal data we hold is accurate and up to date. We would subsequently notify any third party with whom we might have shared your personal data, including processors, and ask them to also update their records.
• To You may request your personal data to be deleted from our records. In order for us to be compliant with our Regulator, this may not be done instantaneously (Please see section “Retention of Data”). Where deletion is permitted, we will also inform any third parties with whom we might have shared your personal data and request them to delete your personal data from their records.
• You may request not to be contacted for any marketing related purposes. This can be done via our “unsubscribe button” or via our privacy email address.
• You can object, at any time, to any decisions that we may take that are purely based on automated processing (including profiling). Profiling involves the use of technology that helps us make decisions automatically, based on your personal data that we collect from you or from third parties
• You may file a complaint. If you are not satisfied with the way that your complaint was handled by GKFX, you can address your complaint to the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel 0303 123 1113), accessicoinformation@ico.org.uk

Sharing Personal Data

GKFX does not sell personal data to third parties. We may share your personal information with third parties for specific purposes, in relation to the performance of our services, our legal obligations or for public interest purposes. Third parties with whom we may share your personal data are:

• The Financial Conduct Authority or/and (when legitimately required so to do) with other
regulatory and government bodies in the UK or other countries.
• Other companies within our group that provide us with IT, administration and other services
• Service providers and specialist advisers who have been contracted to provide us with administrative, financial, insurance, audit, research or other services
• Introducing brokers
• Courts, tribunals and other legal authorities
• Credit reporting or reference agencies
• Credit providers
• Any third party with whom you may authorise us to share your personal data.

Transfers Outside the Eea

We may transfer your personal data outside of the European Economic Area (EEA). In those cases, we ensure that adequacy rules apply or the third party to whom we transfer the data has provided appropriate safeguards on security and confidentiality in relation to the transfer.

Security

We hold personal information in a combination of secure computer storage facilities in electronic and other means, and we take appropriate technical measures to protect personal information from misuse, loss, unauthorised access, modification or disclosure.

Cookies

Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. They are stored on your device (laptop, smartphone, desktop) when you visit a website.
GKFX uses cookies to navigate between its webpages efficiently, to personalise content and ads, to provide social media features, to analyse traffic and to improve the user’s experience. We may also share information about your use of our site with our social media, advertising and analytics partners. You can find more information about cookies www.allaboutcookies.org
You have the option of turning this function off via your browser settings. However, this may affect your ability to view parts of the website or to access certain applications. For information about the cookies on our site, please visit our ‘Use of cookies by GKFX’ page: https://www.gkfx.co.uk/Cookies

GKFX TERMS OF USE (The Terms) updated on 18/05/2018

This website is the property of GKFX and any affiliated to it companies. By using this website you agree to be subject to these Terms of Use, our Privacy Policy and Cookies Policy.

Scope of these Terms

This document sets out the standards that apply when you visit the GKFX website, upload content, use applications that we own or manage, you link to our site, or interact with our site in any other way.
These terms are not directed to the residents of the US, China, or any other country/jurisdiction that we do not business with.

Who we are and how to contact us

www.gkfx.com is a site operated by GKFX Financial Services Limited (GKFX), a company registered in England and Wales with registered address at 24 Bevis Marks London EC3A 7JB. We are authorised and regulated by the Financial Conduct Authority (FCA 501320).

By using our website you accept these Terms

By using our site, you confirm that you accept these Terms and you agree to comply with them.
If you do not agree to these terms, you must not use our website.
We recommend that you print a copy of these terms for future reference.

We may make changes to the Terms

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on 18/05/2018.

Prohibited uses

You may use our site only for lawful purposes. You may not use our site:

• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of our site
• Not to access without authority, interfere with, damage or disrupt:
• any part of our site;
• any equipment or network on which our site is stored;
• any software used in the provision of our site; or
• any equipment or network or software owned or used by any third party, including market data
• charts
• chat room.

Third Party Providers

To perform our services, we collaborate with third parties for market data, research reports, trading platforms and applications. The third party content is provided on an "as-is" basis. We make no warranties or representations regarding the quality, merchantability or fitness for purpose of services or products provided by third parties and separate terms of business apply.

Exclusion of Liability

We accept no liability for any computer virus or other malicious software that you may encounter through accessing our website or applications that we own or manage in collaboration with third parties or due to acts we do not have direct control, including acts of Force Majeure.
GKFX is not liable for any consequential, incidental, special, direct, or indirect damages resulting from the use of this website and applications provided via it.

Exclusion of Warranty

We do not warrant that our website will meet the needs of the user, or that it will be uninterrupted, timely, secure or error-free. We make no warranty that the results obtained from the use of our website will be accurate, fit for purpose or that the quality of services, information, or other material through our sites will meet your expectations.

Indemnification

By accessing and using this website, you agree to indemnify and hold GKFX and any third providers that GKFX collaborates with, harmless from and against any and all claims, losses (direct and indirect), liability, costs and expenses.

Intellectual Property

All intellectual property rights on the content on the GKFX website is the ownership of GKFX Financial Services Ltd and/or any third party providers that GKFX collaborates with. Intellectual Property includes with no limitation trademarks, charts, databases, adverts, prices, market information, product information, website design, logos, copyright, client data, know how. No Intellectual Property Rights belonging to GKFX may be copied, reproduced or published without prior consent from GKFX. Different rules may apply regarding the Intellectual Property of third parties. You would need to read the third-party providers terms of business on Intellectual Property.

Breach of these Terms

When we consider that a breach of these Terms has occurred, we may take such action as we deem appropriate.
Failure to comply with these Terms constitutes a material breach of the terms upon which you are permitted to use our website, and may result in our taking all or any of the following actions:

• Immediate, temporary or permanent withdrawal of your right to use our site
• Closure of your account (demo/active)
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

Governing Law

These Terms are governed by the laws of England and Wales. You and we both agree that the courts of London, England will have exclusive jurisdiction.

Personnel Training and Awareness

All GKFX staff are trained in handling personal data and confidential information on an on going basis.

Date Into Effect

This Policy is effective as of 18/05/2018 and it may be amended from time to time. You will be notified of any amendments via our website or via email.

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Contact Information

DPO, GKFX Financial Services Limited

Bevis Marks House, 24 Bevis Marks, London, EC3A 7JB

+44 (0) 207 186 1250

www.gkfx.com

privacy@gkfx.com