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We have provided the information available on this web site for your general guidance. We take great care in ensuring that the information is accurate; however we accept no liability in this respect. You should be aware that the content is subject to change without notice. The information on this web site is not targeted at the general public of any particular country. It is not intended for distribution to residents in any country where such distribution or use would contravene any local law or regulatory requirement. The services offered on this web site are only available following successful completion of our account opening requirements. We have made every effort to describe the benefits and risks associated with these services which you should ensure you understand before contemplating an application. In the ordinary course of its business, we may hold positions in one or more financial instruments which feature on this web site. You acknowledge and agree that any instruction given by you or on your behalf via our website is made at your own risk. You will be responsible for keeping your account number and password confidential and acknowledge that we shall be entitled to rely upon these details to identify you. All copyright, trademarks and other intellectual property rights in the content of this website belong to us or our licensors. No information on this website may be reproduced, adapted, uploaded to a third party distributed or transmitted in any form by any process without our specific written consent. From time to time, our website may contain links to other sites and/or resources provided by third parties. These links and/or resources are provided for your information only and we have no control over the contents of those materials, and in no way endorse their content. Any analysis, opinion, commentary or research-based material on our website is for information and educational purposes only and is not, in any circumstances, intended to be an offer, recommendation or solicitation to buy or sell. You should always seek independent advice as to your suitability to speculate in any related markets and your ability to assume the associated risks, if you are at all unsure. No representation or warranty is made, express or implied, that the materials on our website are complete or accurate. We are not under any obligation to update any such material. As such, we (and/or our associated companies) will not be responsible or liable for any loss or damage incurred by you or any third party arising out of, or in connection with, any use of the information on our website (other than with regards to any duty or liability that we are unable to limit or exclude by law or under the applicable regulatory system) and any such liability is hereby expressly disclaimed.

Who we are We are committed to protecting your privacy and maintaining the security of any personal information that we receive from you. If our privacy policy changes, we will place an updated version on our website. The purpose of this policy The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity. We are the controller of any personal information which you provide to us which means that we decide the purposes and means of the processing of that personal information. How we obtain and store your information We obtain your information through applications, emails, letters, telephone calls, SMS messages, cookies and conversations when registering for our services and during the course of our relationship (including information gained when you use our learning tools, demo accounts and trading simulators). We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications sent by or to us. We follow strict security procedures in the storage and disclosure of information that you have given us to prevent unauthorised access. What types of personal information we process We may process the following types of personal information: name; contact details including email details and phone numbers; age or date of birth; gender; occupation; income; trading knowledge and experience; user names and passwords; information relating to your account including your account history, activity and orders IP address; National insurance number or other MiFIR national identifier; FCA approved reference number; Transaction reporting reference; Power of attorney / agent details; Phone device type; Operating system; Device ID; Cookie ID; Google 360 ID; GUID; information about your use of our services, products and facilities (including information gained when you use our learning tools, demo accounts and trading simulators); Bank Account Number; Sort Code; Passport Number; Marital Status. How we check your identity To comply with money laundering regulations we need to confirm the name and address of our customers and certain third parties. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit. Using your personal information As well as checking your identity, the personal information we hold may be used for: considering any of your applications; carrying out risk assessments; complying with our legal and regulatory obligations; performing our obligations under any contract we have with you; administering our relationship with you including resolving queries or issues; establishing and managing your account; reviewing your ongoing needs; providing you with the information, products and services that you request from us; checking your instructions to us; investigating any complaint you may make; providing evidence in any dispute or anticipated dispute between you and us; recovering amounts payable; training our staff; enhancing our customer service and products; undertaking product development and analysis; and detecting or preventing fraud or other crimes. Where you have consented to direct marketing, we may send you marketing material from time to time by post, email, telephone, SMS or other electronic messaging services. We also use technology to make decisions automatically or to build profiles about you. This technology uses logic that assesses whether our products are suitable for a potential customer, which helps us to determine whether or not it is appropriate for a potential customer to open an account with us. This means that you may not be able to open an account with us if our technology determines that it would not be appropriate for you to do so based on your financial knowledge and trading experience. If you ever think our machines have got it wrong, you can ask for a human to look into it. (See “Your Rights - Rights in relation to automated decision making and profiling”.) When we may share your information We may share your personal information with: the FCA and any other regulatory or tax authority; such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police; our associated companies; third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you; our introducing brokers and other commercial partners; our professional advisers; our auditors for the purposes of carrying out financial and regulatory audits; our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable, including requesting a reference from your bank or any credit reference agency. Any third party referred to in this clause may share any personal information concerning you with us and other organisations involved in credit reference, the prevention of fraud and/or crime and/or money laundering or for similar purposes or to recover debts involved; courts, tribunals, regulatory or tax authorities and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority or government agency; the purchaser or potential purchaser of one or more of our businesses or product/service lines and their professional advisers; and our trade repository. Please also note that disclosure to the trade repository or regulators may also result in certain anonymous transaction and pricing data becoming available to the public. Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy and comply with the data protection principles and this policy. Information, which we obtain indirectly In some cases, we are also provided with your name and contact details by our introducing brokers. We also gather information relating to you and your online behaviour: to help optimise our website, to give you a good user experience and to personalise your use and our communications to you; to help us monitor, support and improve the performance of our site (by analysing your use and experience of our site); to help us understand more about you and the products and services you use and are interested in; and to tailor the online advertising you receive. Knowing more about you helps us to understand our customers better, and means we can give you recommendations about products and services you may be interested in, and provide you with relevant advertising and customised communications that are of interest to you. We combine information that you provide to us with information that is publicly available and/or that we receive from third parties such as advertisers and/or other reputable sources who have obtained your permission to do so, or have otherwise explained to you that this may happen. Our website uses cookies to operate, personalise and enhance our site performance and to distinguish you from other users. Please see our cookie policy for further details. Joint applicants You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint account or product, this may mean that your personal information will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa. The legal basis for our processing of personal information The legal basis for our processing of personal information will depend on why we process your information. Where you wish to enter into or have signed a contract to receive services from us, we will process your personal information to enable us to enter into and perform our contract with you. If you don’t provide the personal information requested then we may not be able to provide some or all of those services to you. Where you use our website, we will process your personal information collected by using cookies in accordance with our cookie policy. Please click here to view our cookie policy. We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to: performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation; obtaining information about your relevant investment knowledge and experience as required by the FCA so that we can assess whether a service is appropriate for you; obtaining information about your other investment activities in order to ascertain your status for the purposes of regulations which apply to trading in over-the-counter derivatives; and submitting and disclosing reportable data to our trade repository. We also have a legitimate interest to process your personal information for: performing the services or supplying the products or information you have agreed to receive from us; ongoing management of our relationship with you and to maintain contact with you; our internal business purposes which may include business and disaster recovery, document retention/storage, …

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