Introduction

Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data, when and with whom we share it and how we will keep it safe. It also details your rights in respect of our processing of your personal information and how you may exercise them. Please take the time to read and understand this policy.

We may make changes to this Notice from time to time and it is important that you check this Notice for any updates. Any personal information we hold will be governed by the current privacy notice at the given time. If we make changes we consider to be important, we will communicate them to you.

Please note that this notice is addressed to customers and potential customers. If you are an GMOTRADE employee, a contractor to GMOTRADE or a third-party service provider, your personal information will be used in connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us.

Any reference to ‘us’, ‘our’, ‘we’ or ‘GMOTRADE’ in this privacy notice is a reference to each group company within the GMOTRADE as the context requires unless otherwise stated.

Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to any of our customers and potential customers as the context requires unless otherwise stated.

By accessing our websites, including using any of the communication channels to contact us, we consider that you have read and understood the terms of this notice and how we process any information you disclose to us including personal data prior to becoming a client. Once you open an account with us you agree that this notice, including any amendments, will govern how we collect, store, use, share and in any other form process your personal data and your rights during our business relationship and after its termination.

Who may we disclose personal information to?

As part of using your personal information for the purposes set out above, we may disclose your information to:

• other companies within the GMOTRADE  who provide financial and other services;
• third party apps providers when you use our apps, communication systems and trading platforms which are provided to us by third parties;
• service providers and specialist advisers who have been contracted to provide us with services such as administrative, IT, analytics and online marketing optimization, financial, regulatory, compliance, insurance, research or other services;
• introducing brokers and affiliates with whom we have a mutual relationship;
• Payment service providers and banks processing your transactions;
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
• courts, tribunals and applicable regulatory authorities as agreed or authorised by law or our agreement with you
• government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;
• any third-party where such disclosure is required in order to enforce or apply our Terms and Conditions of Service or other relevant agreements;
• anyone authorised by you.

We endeavour to disclose to these third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us.

Our websites or our apps may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.

Management of personal information.

We are committed to safeguarding and protecting personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

We have appointed a Data Protection Officer to ensure that our management of personal information is in accordance with this privacy notice and the applicable legislation.

We require organizations outside the GMOTRADE  who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this privacy notice.

In brief, the data protection measures we have in place are the following:

• we train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals
• requiring our employees to use passwords and two-factor authentication when accessing our systems;
• we apply Chinese walls and employees only have access to the personal data required for the purposes of the tasks they handle.
• We apply data encrypting technologies during data transmission during internet transactions and client access codes transmitted across networks
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
• practising a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and
• employing physical and electronic means such as access cards, cameras and guards to protect against unauthorised access.