ConsensusFX Privacy Policy

Privacy Policy

ADFC Consulting Ltd (“Consensus-FX”, “ConsensusFX”, "the Company", "the Firm", "we", "us" or "our") is a company registered in England and Wales under registration number 10187078
We provide a platform that allows members to provide opinions as to future movements in foreign exchange markets and aggregate such opinions in order to generate a consensus of member’s opinions. We are not regulated and do not offer any form of trading or execution services or advice or trade recommendations of any kind. Any consensus data generated is the aggregate of our members’ opinions and is not our own opinion.
We are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website, you agree to be bound by this privacy policy however, you are free to withdraw your consent anytime by notifying us.

Privacy
We know that you are concerned with how we deal with your personal information. This privacy statement sets out our current policies and demonstrates our commitment to your privacy. Our privacy policy may change at any time in the future for compliance purposes. You agree to revisit this page regularly and your continued access to or use of the Website will mean your consent to the changes.

Purpose of the Data processing
We recognise the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organisation and to ensure efficient and successful outcomes when using this data. We collect your personal data to provide you with our services as specified in our Customer Terms and Conditions and other documents regulating our business relationship with. We only use personal information as appropriate to provide you with a high quality of service and security. We may use the personal data collected from you to verify your identity and contact information and to establish the business relationship with you and to contact you with account information.

Principles of the Data processing
All personal data is: Fairly and lawfully processed; Processed with specified legal basis; Adequate, relevant and not excessive; Not kept for longer than necessary; Processed in accordance with the individual's (data subject's) rights; Secure; and not transferred to other countries without adequate protection.

Personal Data We Collect:
We may collect and process the following data about you: Information that you provide by filling in forms or other elements on our website, mobile application, and in emails; Up-to-date data about yourself and your identity, if you register your personal details to use our service; Data you provide to us in the registration forms; Details of your visits to our website, details of your emails including, but not limited to: traffic data, location data, weblogs and other communication data, the resources that you access, devices and services you use to contact us.
The personal data that we collect from our customers, process and control to provide our services, include: Name, date of birth, address; Contact details such as email address, phone number, postal address, messengers and / or social networks ID; Technical data such as your IP addresses used to access our Website and services, your activity logs in our systems. We may also ask you for information when you report a problem with the Site. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. Subject to the provisions of this policy specified below, you are also entitled to have the Firm erase your personal data, cease further dissemination of the data and potentially have third parties halt processing of the data.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal however, if you choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, you may not be able to use that service or feature. The data we collect depends on the context of your interactions with the Company, the choices you make, including your privacy settings, and the service and features you use. Personal data may consist of data kept on paper, computer or other electronic media all of which is protected under the GDPR.

Your rights
As a data subject which provides its personal data to us you are entitled to:
Obtain from us an information whether your personal data is being processed by us. You may also access your personal data and request us to provide you with a copy of your personal data; Obtain from us without undue delay the rectification of inaccurate personal data. You also have the right to have incomplete personal data completed; Subject to the data protection regulations applicable to you, you may request from the Firm the erasure of your personal data without undue delay.

Reasons we share your personal data
We share your personal data with your consent or as necessary to provide any service you have requested or authorised. To provide you with our services we share your personal data with our partners, vendors and service providers, including IT and software providers and vendors. We may also share your personal data with third parties and authorities if required by law, in respond to legal process, to protect our clients, to maintain the security of our services and to protect the rights or property of the Firm.
We do not sell, license, lease or otherwise disclose your personal data to any third party for any reason, except as described below.
We reserve the right to disclose your personal data to third parties when required to do so by law to regulatory, law enforcement or other government authorities.
As a result, some of your personal data depending on the system where they are kept may be disclosed to our IT vendors. We limit an access of such IT vendors to our information systems to the best of our abilities however, the situation may arise that in the process of software maintenance (modification of software functionality, migrating data to the new software versions, fixing bugs etc.) the vendor and/or IT provider get an access to the databases where your personal data is stored.
We may share information with affiliates, subsidiaries and partners, if the information is required to provide the product or service you have requested, or to provide you with the opportunity to participate in the products or services our affiliates, subsidiaries and partners offer.
We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high- quality products and services that might be of value to our customers. To ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful to yourself. The use of your personal data is limited to the purposes identified in our relationship with the partner or affiliate.
All third parties with which we share your personal data are required to protect your personal data in a manner similar to the Company's. We use a variety of legal mechanisms, including contracts, to help insure your rights and protections. Restriction of responsibility
If at any time you choose to purchase a product or service offered by another company, any personal data you share with that company will no longer be controlled under our Privacy Policy. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a co-branded Web site or to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarise yourself with the privacy policy provided by that third party.
Should you consider that your rights under this Privacy policy and / or applicable legislation are infringed by us and the Firm did not take all necessary actions to remedy such violation or rejected your claim, you have the right to lodge a complaint with a supervisory authority and before the competent court.

Security of Personal Data
We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our staff. We use leading encryption technologies to secure your data on a hardware and software levels. The Firm's staff and third parties, when contracted to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.

Breach of Personal Data
In the case of a personal data breach, the Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority- Information Commissioner's Office, UK (ICO) unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to ICO is not made within 72 hours, it shall be accompanied by reasons for the delay according to the Article 33 of GDPR.

Where Personal Data is stored and processed
Personal data collected by the Company may be stored and processed in your region or in any other country where the Company or its affiliates, subsidiaries or service providers maintain facilities. The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
We transfer personal data from the European Economic Area and United Kingdom to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.

Retention of Personal Data
The Company retains your personal data for the whole period of the business relationship with you and five [5] years from the moment termination of such relationship however, the period of your personal data retention can vary for different data types in the context of various products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for example:
The period of data processing needed to provide the services. This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.

Use of Cookies
Cookies are small text files sent from the Web server to your computer. We use cookies to assist us in securing your trading activities and to enhance the performance of our Website. Cookies used by us do not contain any personal information, nor do they contain account or password information. They merely allow the site to recognise that a page request comes from someone who has already logged on.
We may share Website usage information about visitors to the Website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear GIFs or web beacons) may be used to note the pages you have visited. The information collected by the advertising company using these pixel tags is not personally identifiable.
To administer and improve our Website, we may use a third party to track and analyse usage and statistical volume information including page requests, form requests, and click paths. The third party may use cookies to track behaviour and may set cookies on behalf of us. These cookies do not contain any personally identifiable information.

Changes to this Privacy Policy
From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be disclosed to the websites and we will post a notice on our websites informing you of such changes.
You agree to accept posting of a revised Privacy Policy electronically on the website as actual notice to you and therefore confirm the consent. Any dispute over our Privacy Policy is subject to this notice and our agreement with you. We encourage you to periodically check and review this policy so that you will always know what information we collect, how we use it, and to whom we disclose it. If you have any questions that this statement does not address, please contact us.

Contact
If you have a privacy concern, complaint or a question please contact us using the contact details provided on our web site or mobile application. Unless otherwise stated, the Firm is a data controller for personal data we collect through the services subject to this statement.