FXBFI

Broker Financial Invest Ltd

(Regulated by the Cyprus Securities & Exchange
Commission)

PRIVACY POLICY

Last Updated on June 2018



TABLE OF CONTENTS
1 INTRODUCTION ................................................................................................................................ 3
2 YOUR PRIVACY IS IMPORTANT TO FXBFI ................................................................................. 3
3 PRIVACY POLICY UPDATES .......................................................................................................... 3
4 WHY DOES FXBFI COLLECT PERSONAL INFORMATION ........................................................ 4
5 WHAT KIND OF PERSONAL INFORMATION DO WE ASK FOR? ............................................. 4
7 HOW IS YOUR PERSONAL DATA COLLECTED? ........................................................................ 5
8 HOW DO WE USE THIS INFORMATION AND TO WHOME WE MAY DISCLOSE IT? ........... 5
9 HOW LONG WILL YOU USE MY PERSONAL DATA FOR? ........................................................ 6
10 MANAGEMENT OF PERSONAL INFORMATION ......................................................................... 6
11 HOW DO WE STORE PERSONAL INFORMATION? ..................................................................... 6
12 HOW TO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE ................. 7
13 WHAT IS A COOKIE AND HOW DO WE USE COOKIES ............................................................. 7
14 LINKS TO THIRD PARTY WEBSITES ............................................................................................ 8
15 YOUR LEGAL RIGHTS ..................................................................................................................... 8
16 NO FEE USUALLY REQUIRED ....................................................................................................... 9
17 TIME LIMIT TO RESPOND ............................................................................................................... 9
18 WHAT IF YOU HAVE A COMPLAINT? .......................................................................................... 9
19 HOW TO CONTACT US .................................................................................................................... 9
20 PRIVACY: WEB SUPPLEMENT ..................................................................................................... 10
20.1 Technology improvements ......................................................................................................... 10
20.2 Choice and Opt-out .................................................................................................................... 10
21 QUERIES ........................................................................................................................................... 10

1 INTRODUCTION

FXBFI Broker Financial Invest Ltd (hereafter the “Company” or “FXBFI” or “we, us, our”) is
regulated by the Cyprus Securities and Exchange Commission under license 315/16. This Privacy
Policy explains the way FXBFI collects, uses and manages personal information from its active
clients and potential clients. FXBFI is committed to safeguarding your privacy. By opening a
trading account with FXBFI, the client gives consent to such collection, processing, storage
and use of personal information by FXBFI as explained below.

2 YOUR PRIVACY IS IMPORTANT TO FXBFI

It is the Company’s policy to respect the confidentiality of information and the privacy of
individuals. FXBFI is bound by the Data Protection Principles contained in the Processing of
Personal Data (Protection of Individuals) Law of 2001, as amendment in 2003, the Regulation of
Electronic Communications and Postal Services Law of 2004 and The General Data Protection
Regulation (GDPR) (EU) 2016/679 effected as from the 25th of May 2018.
This Privacy Policy aims to give you information on how we collect and processes your personal
data, including any data you may provide through our website when you sign up to our website.
It is important that you read this Privacy Policy together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
Policy supplements the other policies and is not intended to override them.

3 PRIVACY POLICY UPDATES

FXBFI’s Privacy Policy Statement will be reviewed from time to time to take account of new laws
and technology, changes to our operations and practices and to make sure it remains appropriate
to the changing environment. Any information we hold will be governed by the most current
Privacy Policy Statement. The revised Privacy Policy will be uploaded in the FXBFI website. In
this respect, the clients hereby agree to accept posting of a revised Privacy Policy electronically
on the website as the actual notice of FXBFI to its clients. If any of the changes made are of
material importance then we will notify you by email or by means of a notice on the home page.
Any dispute over FXBFI’s Privacy Policy is subject to this notice and the Client Agreement.
FXBFI encourages its clients to periodically review this Privacy Policy so that they are always
aware of what information FXBFI collects, how it uses it and to whom it may disclose it, in
accordance with the provisions of this Policy.

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4 WHY DOES FXBFI COLLECT PERSONAL INFORMATION

Our goal is to fully satisfy our customers' requirements whilst meeting our regulatory obligations.
To do this effectively, we need to collect certain personal information. It is your choice to provide
FXBFI with the information required and requested, however any missing information may result
in its being unable to provide you with trading services.

5 WHAT KIND OF PERSONAL INFORMATION DO WE ASK FOR?

In order for FXBFI to provide its clients with the investment services, FXBFI is required to collect,
process and retain personal data of its clients in accordance with mandatory legal requirements.
The type of personal information we may collect can include (but is not limited to)

• Personal information such as your name, address, date of birth, telephone number
• Financial details such as your estimated annual income, estimated net worth, your financial
investment experience and knowledge;
• Documents that you provide to us to verify your identity, such as your passport or ID card,
utility bills and/or bank statement.
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you].
• Technical Data includes [internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to access this website].
• Profile Data includes [your username and password, purchases or orders made by you,
your interests, preferences, feedback and survey responses].
• Usage Data includes [information about how you use our website, products and
services].
• Marketing and Communications Data includes [your preferences in receiving
marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does 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 notice.

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We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and biometric
data). Nor do we collect any information about criminal convictions and offences

7 HOW IS YOUR PERSONAL DATA COLLECTED?

We obtain most of the information directly from our customers through application or other forms,
and from maintaining records of information provided in the course of ongoing customer service.
We may also obtain information from other sources. This may include, but not limited to, site areas
visited, pages viewed, frequency and duration of visits, Internet Protocol (IP) address, computer
identification parameters, types of transactions conducted and documents downloaded. We may
ask for other information voluntarily from time to time (for example, through market research,
surveys or special offers) to enable us to improve our service or consider the wider needs of our
customers or potential customers.

8 HOW DO WE USE THIS INFORMATION AND TO WHOME WE MAY DISCLOSE

IT?

The main purpose we use your personal information for is to enable us to understand your financial
objectives and ensure that relevant services are appropriate to your profile. Further, this
information helps FXBFI to provide quality services. While we may send you marketing material
(including but not limited to SMS or email communication for you to view, margin calls, or other
information) from time to time that we think will be useful to you, we are conscious of the need to
respect your privacy. Unless you are informed otherwise, the personal information we hold is used
for establishing and managing your account, reviewing your ongoing needs, enhancing customer
service and products and giving you ongoing information or opportunities that we believe may be
relevant to you.

FXBFI will not disclose your personal information without your prior consent however,
depending on the product or service concerned and particular restrictions on sensitive
information, this means that personal information may be disclosed to:

• Service providers and specialist advisers to FXBFI who have been contracted to provide
us with administrative, financial, insurance, research or other services.
• Introducing brokers or partners with whom we have a mutual relationship (any of whom
may be within or outside the European Economic Area)
• Credit providers, courts, tribunals and regulatory authorities as agreed or authorized by
law

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• A Trade Repository or similar under the Regulation (EU) No 648/2012 of the European
Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties
(CCPs) and trade repositories (TRs) (EMIR)
• Credit reporting or reference agencies, third authentication service providers, fraud
prevention, anti-money laundering purposes, identification or due diligence checks of the
client
• Anyone authorized by an individual, as specified by that individual or the contract
• To an Affiliate of the Company or any other company in the same group of the Company.

In case such disclosure is required to be made by law or any regulatory authority, it will be made
in order for FXBFI to comply with any legal obligations, protect itself from potential fraud, and
maintain service provider agreements. In case such disclosure is required it will be made on a
‘need-to-know’ basis, unless otherwise instructed by the regulatory authority. Generally, we
require that organizations not under FXBFI Broker Financial Invest Ltd who handle or obtain
personal information as service providers to FXBFI acknowledge the confidentiality of this
information, undertake to respect any individual's right to privacy and comply with the Data
Protection Principles and this policy.

9 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

FXBFI is obligated by the present regulations to keep your data on record for a period of five (5)
years which starts counting after the execution of the transactions or the end of the business
relationship.

10 MANAGEMENT OF PERSONAL INFORMATION

FXBFI trains its employees who handle personal information to respect the confidentiality of
customer information and the privacy of individuals. FXBFI regards breaches of your privacy very
seriously and will impose appropriate penalties, including dismissal.

11 HOW DO WE STORE PERSONAL INFORMATION?

Safeguarding the privacy of your information is important to us, whether you interact with us
personally, by phone, mail, over the internet or other electronic medium. We hold personal
information in a combination of secure computer storage facilities and paper-based files and other
records and take steps to protect the personal information we hold from misuse, loss, unauthorized
access, modification or disclosure. As stated above, FXBFI is obligated by the present regulations

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to keep your data on record for a period of five (5) years which starts counting after the execution
of the transactions or the end of the business relationship.

12 HOW TO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE

FXBFI endeavors to ensure that the personal information it holds is accurate and up-to-date. We
realize that this information changes frequently with changes of address and other personal
circumstances. We can generally update your customer information over the telephone. Clients
consent to the receipt of such contact when they agree to our terms and conditions of use when
registering with FXBFI. Any person wishing to opt out of further contact with FXBFI at any time
whatsoever is entitled to do so, simply by contacting FXBFI either by phone or email and
requesting that no further contact on behalf of HY Options be made. In addition, FXBFI may, on
occasion, seek to contact clients, either by phone or by email, for the purpose of informing them
of unique promotional offerings provided by FXBFI for the client.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.

13 WHAT IS A COOKIE AND HOW DO WE USE COOKIES

Cookies are small pieces of text stored on your computer to help us determine the type of browser
and settings you are using, where you have been on the website, when you return to the website,
where you came from, and to ensure your information is secure. The purpose of this information
is to provide you with a more relevant and effective experience on the FXBFI site, including
presenting web pages according to your needs or preferences.
FXBFI may also use independent external service providers to track the traffic and usage on the
website.
Cookies are frequently used on many websites on the internet and you can choose if and how a
cookie will be accepted by changing your preferences and options in your browser. You may not
be able to access some parts of www.fxbfi.com if you choose to disable the cookie acceptance in
your browser, particularly the secure parts of the website. We therefore recommend you enable
cookie acceptance to benefit from all the services on the website.
FXBFI has a separate Cookie Policy which describes how we use cookies in the context of our
operations with particular reference to the types of cookies and how these can be enabled or
disabled.

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14 LINKS TO THIRD PARTY WEBSITES

The FXBFI website may have links to external third party websites that may benefit the user.
Please note, however, that third party websites are not covered by FXBFI privacy policy and these
sites are not subject to FXBFI privacy standards and procedures.

15 YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your
personal data:

Ø Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check
that we are lawfully processing it.
Ø Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to
verify the accuracy of the new data you provide to us.
Ø Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to comply with
your request of erasure for specific legal reasons which will be notified to you, if applicable,
at the time of your request.
Ø Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may demonstrate that
we have compelling legitimate grounds to process your information which override your
rights and freedoms.
Ø Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us
to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we no longer require it
as you need it to establish, exercise or defend legal claims; or (d) you have objected to our

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use of your data but we need to verify whether we have overriding legitimate grounds to
use it.
Ø Request the transfer of your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
Ø Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide
certain products or services to you. We will advise you if this is the case at the time you
withdraw your consent.

16 NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

17 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.

18 WHAT IF YOU HAVE A COMPLAINT?

If you consider that any action of FXBFI breaches this Privacy Policy Statement or the Data
Protection Principles or otherwise doesn't respect your privacy, you can make a complaint. This
will be acted upon promptly. To make a complaint please refer to our Complaints Handling Policy.

19 HOW TO CONTACT US

If you want to:

• make a general enquiry about FXBFI privacy policy;
• to exercise any of your legal rights in relation to your personal data;
• make a complaint in relation to your personal data;

Please contact the DPO using the following contact details:

[email@info.fxbfi.com]
Contact number: at +357 25 262828
Mailing Address: FXBFI Broker Financial Invest Ltd, 1 Arch. Kyprianou and Agiou Andreou
Corner, Loucaides Building, 2nd floor, Office 21, 3036 Limassol, Cyprus.

20 PRIVACY: WEB SUPPLEMENT

This statement outlines some privacy issues specific to the www.fxbfi.com website.

20.1 TECHNOLOGY IMPROVEMENTS

FXBFI is constantly striving to improve functionality on this site through technology
changes. This may mean a change to the way in which personal information is collected or
used. The impact of any technology changes which may affect your privacy will be notified
in this Supplement at the time of the change.

20.2 CHOICE AND OPT-OUT

During the registration process with FXBFI, you will be presented with the option to opt-
in and/or opt-out of - subscribing to the following additional services, as applicable:
• Marketing services, which provides you with information regarding the products and
services offered by FXBFI or its partners; and opportunities that we believe may be
relevant to you
• Newsletters
• SMS (text) messages
• Other electronic communications.
If you no longer wish to receive the above mentioned communications, you may opt-out of
receiving them by following the instructions included in each communication.

21 QUERIES

Should you have any additional questions or concerns regarding this Policy, please kindly contact
us at any time at info@fxbfi.com or call us at +357 25 262828.

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