1. our practices regarding the collection, use, and disclosure of certain information, including your personal information, by Compare Forex Brokers Pty Ltd (ACN 605 274 324)(Compare Forex); and
2. our commitment to protecting the privacy of your personal information that we collect through our website (the Site) or directly from you, being the person, organisation or entity that uses our Site (referred to as you or your).
Security of Data
At Compare Forex Brokers Pty Ltd, your privacy is important to us. The Site is secured with an SSL licence
We ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (Privacy Principles) contained in the Privacy Act 1988 (Cth) (Privacy Act).
Collection of Information
The below section sets out how we receive and store information about you. This includes, information you provide to us (Information You Provide), information we collect automatically (Information we Collect) and information from other sources (together, Personal Information).
If you use our Site we may collect information such as your name, iPhone or android smartphone device identification details (Device IDs) and locational data sent by your device, your email address, date of birth, information about products or services you are interested in and other information required to provide our Site. In particular, such information will be collected when you fill out a contact us form.
Pursuant to the below, the types of Personal Information we expect to collect from you includes but is not limited to any of the following:
2. email address;
3. device identification details;
5. trading patterns;
6. specific trading information; and
7. any other information requested on our Site otherwise requested by us or provided by you.
Information You Provide
We collect Information You Provide to us which includes:
1. device identification details;
3. Clickstream Data;
4. specific trading information; and
5. trading patterns
We collect this information in a number of ways, including when you interact with our Site or personnel, or participate in surveys or marketing promotions.
Information we Collect
Compare Forex will also collect information about you and your use of our Service, your interactions with us (including our personnel) and our advertising, as well as certain information regarding your Devices used to access our Service.
This information includes:
1. your activity on our Site;
2. your interactions with our system (including any email, push notification and text messaging);
3. details of your interactions with our personnel (such as the date, time and reason for contacting us);
4. Device IDs or other identifiers;
6. Device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information.
Your use of our Services
As with most online businesses, we may log information about your access and use of our Services, including your general use of our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
Your opinion and feedback: We may contact you to voluntarily respond to questionnaires, surveys or market research to seek your opinion and feedback. Providing this information is optional to you.
Information from other sources
For example, when you use a Broker website, that Broker may pass information back to us (including for commission purposes).
Collection and Use of Personal Information Services
Through our Services, we collect and use the information for purposes including:
• for internal record keeping;
• for market research and business development including website development;
• for marketing;
• to run competitions or offer additional benefits to you;
• for data analytics purposes;
• assisting us to improve our products and services and making them more relevant to you;
• assisting us to improve our website;
• optimise content selection, recommendation algorithms and delivery;
• otherwise managing our internal business operations and processes; and
• with your consent which can be rescinded at any time by email in accordance with the contact provisions of this policy, for automated decision making in processing your personal information for some of the services or products we provide (you can at any time request a manual review of the accuracy of an automated decision).
Compare Forex does not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information.
Where unsolicited information is received by us, we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information. If it would not be permitted for Compare Forex to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, Compare Forex may retain the information in accordance with the terms of this policy.
Compare Forex collects anonymous information to:
• provide aggregated reports to Brokers;
• monitor the use of our Site;
• help us make improvements to the Site; and
• offer relevant information and services to as many users as possible.
Use of Data for Marketing
We will only send you direct marketing materials (including exclusive offers and information about our Services or other services, where you have indicated consent.
Transfer of Information
By using our Services you consent to Us sharing, where required for the provision of our Services, any and all of your information with Brokers.
To protect the Personal Information that we provide to any Brokers, we will enter into contracts with Brokers to require the protection of your Personal Information. Compare Forex may also share your information if requested by law, to prevent any illegal activity and defend third party claims against Compare Forex.
Transfer of Information Outside Australia
Compare Forex may transfer your personal information to our related entities, Brokers and third party service providers based in Australia or overseas (including in the USA, UK, Europe, Asia or Australia).
Links to Other Websites Including Forex Brokers
The Site directs users to third-party websites (including websites operated by Brokers). These websites are beyond Compare Forex’s control.
To the greatest extent possible under the relevant laws, we are not responsible or liable for any linked websites or apps not owned or controlled by us including their content, use of apps, or their privacy practises
Links to websites allow users to “click” to third party websites. These “clicks” may be tracked by third-party software (such as analytics) which record what the user does once they are on these websites (including recording when a user sets up an account with a Broker).
Information we do not collect
Compare Forex Brokers does not collect information from you in relation to:
• your race or ethnic origin;
• your political opinions;
• your religious or philosophical beliefs;
• your trade union memberships;
• your genetic or biometric data;
• your health or mortality; and
• your sex life or sexual orientation.
Storage and Security
We take our obligations to protect your Personal Information very seriously. This includes ensuring that we meet the Office of the Australian Information Commissioner guidelines with respect to the appropriate level of information and software security, governance and associated procedures so as to adequately protect your Personal Information from unauthorised access, loss, misuse, disclosure or alteration.
Your information may be linked to the data stored in the cookie. If requested by you, we will assist you to remove our cookies and or web beacons.
Web beacons or clear.gifs are small pieces of code placed on a web page to monitor the visitors’ behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons on our Site time to time in addition to Facebook Pixels, Google analytics and other similar code. Facebook Pixels, Google analytics and other similar codes are used to analyse and track site visitors and to understand the actions site visitors take on websites.
In the course of providing Services to you, we may use geotracking or other geolocation technology, if you consent. We may use geotracking to personalise suggested items you may be interested in and to provide you with a better user experience and geotracking is intended so that our Services are useful at particular locations.
Links to other services
Our Services may also contain links to other websites of interest. We do not have any control over those websites. To the greatest extent possible under the relevant laws, we are not responsible for or liable for the protection and privacy of any information which you provide whilst visiting such websites.
We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that this information may change frequently with changes of address and other personal circumstances. If at any time you would like to access, correct or change any personal information provided to us by you, please contact our privacy officer by email at firstname.lastname@example.org. Please note that where you require copies of your personal and/or sensitive information held by us, we may charge you a reasonable fee for the postage and administration involved in complying with any such request.
Each Information Subject has the right to:
• access the data we hold about you;
• be informed (including being informed about what data is being processed and how and why it is being processed as well as being informed about anyone else the data may be passed to);
• rectify your data (including the right to have your data modified or corrected)
• erase your data (including the right to request the deletion of your data in certain circumstances such as where you withdraw your consent, deletion of data where your data is no longer required for the collection purpose or deletion of your data where it has been unlawfully processed).
• restrict processing of your data (including the right to ask for any temporary stop to procession);
• take your data (including the right to ask us to provide you with any of the data you supplied directly to the Data Controller in a useable form);
• object (including the right to object to additional processing of your data which is inconsistent with the reason for which it was collected and including the right to object to profiling, automation, and direct marketing); and
• right not to be subject to a decision based solely on automated processing.
Controlling your Personal Information
We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider it appropriate to take in response. If you are still not satisfied after having contacted us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner.
• “we”, “our” and “us” refers to Compare Forex and its successors and assignees and appointed Data Controller.
• “Clickstream Data” refers to data that is collected by the server when you visit the Site (including elements such as your browser, system, location and traffic source such as Google).
• “Data Controller” refers to Compare Forex.
• “Data Protection Officer” refers to Justin Grossbard.
• “Device” refers to any mobile phone, tablet or other device capable of running the Software.
• “Held Information” means:
• The personal information we hold in relation to you;
• Why we process your personal information;
• Who we provide access to in relation to your personal information;
• How and if this personal information is being processed in automated decisions; and
• The processes we use in relation to your information.
• “Information Subject” means a person or persons whose personal information is collected by Compare Forex.
• “Service” or “Services” refers to the functions, services, uses and content of the Site.
• “Subject Access Request” means a user access request.
More information about Australian privacy law is available from the Federal Privacy Commissioner’s website: https://www.oaic.gov.au/
Last update – 17th of February 2020