SGM-FX Limited (“SGM-FX”) (also “we” and “us”) is committed to respecting and protecting your privacy.

Privacy Policy dated: July 2023

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 also, via Google Analytics, collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Cookies

Our Websites use cookies to distinguish you from other users of our Websites. This helps us to provide you with a good experience when you browse our sites, and also allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie policy at https://www.sgm-fx.com/cookies/

We use information in the ways set out below

Under the General Data Protection Regulation (GDPR) (and UK General Data Protection Regulation (UK GDPR)_in the UK), the lawful bases we may rely on for processing your data are:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• We have a contractual obligation for a contract we have entered with you, or are about to enter with you;
• We need to comply with a legal obligation; or
• You consent for a specific purpose, as identified below.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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 promote our services to you;
• 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.

Marketing

We may use your personal data provided to us to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used our services and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a transaction.

Choice

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.

Storage

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.

We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this privacy policy, and for as long as we are required to keep it by law. We will keep your name, address, contact details, any documents provided through your account and any electronic data relating to your trades and account activity for five years from the date which you close your account held with us for the purpose of complying with legal requirements.

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;
  • To our case management platform (Synergies);
  • 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 and European Commission have stated that transfers of data between the UK and the EEA are permitted. This will be kept under review.

If you are a client and based outside the EEA, then there will be limited international personal data transfers when you communicate with us. However, in general your personal data will not be transferred, or stored, outside of the European Economic Area (“EEA”) without your prior written consent.

Security

We maintain appropriate administrative, technical and physical safeguards to protect your personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Rights

SGM-FX will be the data controller of your personal data. We have appointed Bence Molnar, 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 [email protected] 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

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check frequently to see any updates or changes to our privacy policy.

Contact Us

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 protected].

How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected].

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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk