FOREX HORSEMEN INC. (hereinafter referred to as “Forex”, “we”, “us” or “our”) operates a platform that allows users to participate in educational services in the field of security trading, as well as forums, chat rooms and social networking services of Forex and related services made available by Forex (collectively, the “Services”), which Services are accessible through our website or applications for your mobile or other device (the “Platform”).
Collection and Use of Information
Personal information is information about an identifiable individual that is recorded in any form (“Personal Information”). You may be asked to provide your Personal Information anytime you are in contact with Forex or a company affiliated to Forex. Forex and its affiliates may share this Personal Information with each other and use it in accordance with this Policy. They may also combine it with other information to provide and improve the Platform, our Services and advertising.
You are not required to provide the Personal Information that we request. However, if you chose not to do so, we may not be able to provide the Platform or the Services to you or respond to any queries you may have.
Forex receives, stores and processes Personal Information that you make available to us when accessing or using the Platform and Services, such as when you:
Create an account, download a software update, complete psychological evaluations, complete risk management assessment, send us trading and chart analysis, contact us or participate in an online survey or contest. In such case, we may collect a variety of information, including without limitation, your name, mailing address, phone number, email address and contact preferences; link your Forex account to a third-party site (e.g., Facebook, Trading View, Oanda, Optimus Futures, Truity, ICMarkets). In such case, we may obtain information that you have provided to this third-party site, to the extent allowed by your settings with said thirdpart site and authorized by you; and share your content with family and friends using the Platform, or invite others to participate in the Services or in a forum, chat room or social networking service of Forex. In such case, Forex may collect the information you provide about those people, such as name, mailing address, email address and phone number.
The Personal Information received, stored and processed is used by Forex for various purposes, including, without limitation:
to allow us to understand how you use and interact with our Services and the people and things you are connected to and interested in, and allows us to keep you updated on our latest service announcements, software updates and upcoming promotional events. Please note that, if you do not wish to be on our mailing list, you may opt out anytime by updating your preferences; to help us create, develop, operate, deliver and improve the Platform and our Services, content and advertising and for loss prevention and anti-fraud purposes; to verify your identity, to assist with identification of users and to determine appropriate services; to send important notices, such as communications about purchases and changes to our terms, conditions and policies. Since this information is important to your interactions with Forex, you may not opt out of receiving these communications; for internal purposes, such as auditing, data analysis and research to improve the Platform and our Services and customer communications; and to administer a sweepstake, contest or similar promotion.
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may receive, store, process, transfer and disclose non-personal information for any purpose, as further described hereunder: information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Forex or logged in to your Forex account, including, without limitation, the hardware and software you are using, your IP Address, date/time stamp and clickstream data to further develop the content and our Services; when using particular features of the Platform and to provide location based services, Forex and its affiliates may receive, store and process different types of information about your location, including general information (for example, Internet Protocol (IP) address, language, postal code/zip code) and more specific information, including, without limitation, the real-time geographic location of your mobile or other device, GPS-based functionality on mobile or other devices used to access the Platform or specific features of the Platform. Where available, location-based services may use GPS, Bluetooth and your IP address, along with crowd-sourced Wi-Fi hotspot and cell tower locations and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Forex and its affiliates to provide and improve location-based Services; the Platform, email messages and advertisements may use “cookies” and other technologies such as web beacons. We may also allow its affiliates to use their cookies and other tracking technologies on the Platform. These technologies help us better understand user behaviour, tell us which parts of the Platform people have visited and facilitate and measure the effectiveness of advertisements and web searches; we may collect and store details of how you use the Platform and our Services, including search queries. This information may be used to improve the relevancy of results provided by the Platform. Except in limited instances to ensure the quality of the Platform and our Services over the Internet, such information will not be associated with your IP address; we may collect data about your activities from its affiliates, such as information from an affiliate when we jointly offer services or about your experience or interaction with said affiliates; pixel tags enable us to send email messages in a format that customers can read and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers; and with your explicit consent, we may collect data about how you use the Platform in order to help further develop and improve same.
We use the aforementioned information to understand and analyze trends, to administer our website, to learn about user behaviour on the Platform, to improve the Platform and our Services and to gather demographic information about our user base as a whole. This information about all of our users or specific groups/categories of users is combined together so that it no longer identifies or refers to any individual in particular (“Aggregate Information”). Aggregate Information, which is considered nonpersonal information for the purposes of this Policy, helps us provide more useful information to our customers and understand which parts of our Platform and Services are of most interest. We may share Aggregate Information with third parties, including, without limitation, advertisers and investors.
Please note that, to the extent IP addresses or similar identifiers are considered Personal Information by applicable law, we consider these identifiers as Personal Information. Similarly, if we do combine nonpersonal information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
If you access the Platform through a mobile or other device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location tracking functions on your device, provided your device allows you to do this. Please refer to your device manufacturer’s instructions for further details. Some location-based services offered by Forex, such as the geo-location feature, require your Personal Information for the feature to work. You may withdraw consent to Forex and its affiliates and/or partners’ and licensees’ collection, use, transmission, processing and maintenance of location and account data at any time by not using the location-based features and turning off the Location Services settings (as applicable) on your mobile or other device.
In some of our email messages, we use a “click-through URL” linked to content on the Platform. If you click one of these URLs, you will pass through a separate web server before arriving at the destination page on the Platform. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Monitoring of User Communications
We may, either directly or through third party companies and individuals engage by us, review, scan or analyse your communications with other users exchanged via the Platform for fraud prevention, investigation, risk assessment, regulatory compliance, research and product development and customer services purposes. We may also review, scan or analyse messages for research and product development purposes to help optimize searching and communications, as well as to render the Platform more efficient. Please note that we will not sell these reviews or analyses of communications to third parties.
By using the Platform, you acknowledge and agree that Forex, in its sole discretion, may, either directly or through third party companies and individuals we engage to provide services to us, review, scan, analyse and store your communications, whether done manually or through automated means. However, you acknowledge and agree that Forex (i) does not pre-screen or approve your communications with other users exchanged via the Platform; and (ii) shall have the right (but not the obligation) in its sole discretion to refuse, delete or remove any user content made available on the Platform which contravenes the present Policy.
Disclosure to Third Parties
Personal Information will only be shared by Forex to provide or improve the Platform and the Services, as well as related advertisement. However, it will not be shared with third parties for their marketing purposes.
At times, we may make certain Personal Information available to affiliates that work with us to provide the Platform or the Services, or that help develop our marketing strategies, as described hereunder:
Information Shared with any company affiliated to Forex
When you accept to engage in any activity with any company affiliated to Forex through the Platform, your Personal Information is provided to the affiliated company, just as it would if you would engage in said activity by telephone, email or through the affiliated company’s website. If you provide a mobile phone number or email address, said affiliated company may communicate with you directly.
In addition, we may share with our affiliated companies summary reports of feedback from our users. If you choose to provide feedback about your experience with any given Service or product through the Platform, such feedback may be shared with other Forex users and our affiliated companies. Although your feedback may be shared anonymously, you are responsible for the Personal Information you choose to share or submit in these instances.
Other Service Providers
We may shares Personal Information with companies who provide services, such as information processing, extending credit, fulfilling customer orders, delivering products or services to you, managing and enhancing customer data, providing customer service, assessing your interest in the Platform and/or the Services and conducting customer research or satisfaction surveys. These companies are obligated to protect your Personal Information and may be located wherever Forex operates.
Disclosure Pursuant to Applicable Law, etc.
Pursuant to applicable law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence, it may be necessary for Forex to disclose your Personal Information. We may also disclose your Personal Information if we determine that: (i) for purposes of national security, law enforcement or other issues of public importance, disclosure is necessary or appropriate; and/or (ii) disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger or sale, we may transfer any and all Personal Information we collect to the relevant third party.
Protection of Personal Information
You play an important role in keeping your Personal Information secure. You should not share your user name, password or other security information for your Forex account with anyone. If we receive instructions using your username and password, we will consider that you have authorized the instructions.
When you use the Platform or any of our Services or posts on a forum, chat room or social networking service of Forex, the Personal Information and content you share is visible to other users and can be read, collected or used by them. You are responsible for the Personal Information you choose to share or submit in these instances. When you share information or content using said features, you should carefully consider what you are making public.
Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into your account at http://www.forexhorsemen.com or through the Forex application. For other Personal Information we hold, we will provide you with access for any purpose including, without limitation, to request that we correct the data if it is inaccurate or delete the data if Forex is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests can be made through our website, at www.forexhorsemen.com or through the Forex application.
Moreover, you can close your account with Forex by contacting us at the following address: email@example.com. Please note that we may retain certain information for the period necessary to fulfill the purposes outlined in this Policy, such as for analytical purposes or recordkeeping, unless a longer retention period is required or permitted by law.
The Platform and the Services are not directed to persons under the age of 16. Accordingly, we do not knowingly collect, use or disclose Personal Information from persons under 16, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. If we learn that we have collected the Personal Information of a person under 18, or equivalent minimum age depending on jurisdiction, without first receiving verifiable parental consent, we will take steps to delete the information as soon as possible and termination the person’s account. In addition, if you become aware that your child has provided us with Personal Information without your consent, please contact us at the following email address: firstname.lastname@example.org.
Third-Party Sites and Services
The Platform and Services may contain links to third-party websites, products and services. Our Services may also use or offer products or services from third parties. Information collected by third parties or companies affiliated to Forex, including, without limitation, Trading View, Oanda, Optimus Futures, Truity, ICMarkets, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you have any questions or concerns about our Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at the following email address: email@example.com. All such communications are examined and replies are issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavour to provide you with information about relevant complaint avenues that may be applicable to your circumstances.
Modifications to this Policy
Forex reserves the right to modify this Policy at any time. Such modifications will be effective immediately and incorporated into this Policy. Your continued use of the Platform and the Service following any such changes will be deemed acceptance thereof. When we change the Policy in a material way, a notice will be posted on our website or by email along with the updated Policy.
REVISION DATE: April 2017.