Definitions
In this policy "we", "us" and "Fexenvance" mean the business operating this website and platform. "You" means the person using the website or services. "Personal data" means any information that identifies you or can be used to identify you. "Processing" means anything we do with it, from collecting to deleting.
Personal data
The data we may collect includes your first and last name, email address, telephone number and the content of any message or request you send us. When you proceed with an account we may also collect your date of birth, address, identity documents and payment details needed for verification and for deposits and withdrawals.
Usage data
When you visit the site, our servers and tools automatically record technical information such as your IP address, browser type, device, pages viewed, time spent and the page that referred you. We use it to keep the site secure, to understand how it is used and to fix faults.
Cookies
Cookies are small files placed on your device. We use essential cookies to make forms and sessions work, and, where you agree, analytics cookies to measure traffic. You can change or delete cookies in your browser settings, though some parts of the site may not then work properly.
Data controller and processors
Fexenvance is the controller of the personal data described here, meaning that we decide why and how it is used. Companies that handle data for us on our instructions, such as hosting providers, are processors and are bound by contract to protect it.
Collection and use of information
We use your data to answer your enquiries, to set up and run your account, to arrange the call from your personal manager, to provide the service you ask for, to verify your identity, to prevent fraud and to meet legal obligations. If you agree, we also use contact details to send news and offers.
Legal bases under the UK GDPR
We rely on the following bases. Contract: where we need your data to provide the service you requested. Legal obligation: where the law requires us to hold or share it, for example anti-money laundering rules. Legitimate interests: to keep the platform secure, prevent fraud and improve our service, after balancing those interests against your rights. Consent: for marketing messages and non-essential cookies, which you can withdraw at any time.
Retention of data
Enquiry data is kept for up to 24 months after our last contact with you, unless you become a client. Account and transaction records are kept for as long as you hold an account and for five years afterwards, as the anti-money laundering rules require. Usage logs are kept for around 12 months. Marketing consent records are kept until you withdraw consent plus a short period to prove that we honoured the request.
Transfer of data
Some of our suppliers are located outside the UK. When we transfer data abroad we make sure there is an adequate level of protection, for example because the destination has been recognised as adequate by the UK government or because we use the International Data Transfer Agreement or the UK addendum to standard contractual clauses.
Disclosure of data
We may disclose data if we are required to by law, by a court or by a regulator, to prevent or detect crime, to protect our rights or the safety of others, or as part of a business transfer, in which case the receiving party must keep to this policy.
Who receives your data
Categories of recipient include the licensed entities through which services are provided, affiliated companies, IT and hosting suppliers, identity-verification and payment providers, professional advisers, and public authorities such as HMRC, the Financial Conduct Authority and law enforcement where the law requires. We do not sell your personal data.
Security
We use encryption, access controls, staff training and monitoring to protect your data. No online system is completely secure, so we also ask you to protect your login details. If a breach is likely to harm you, we will tell you and, where required, the Information Commissioner's Office. See also Security.
Your rights
You have the right to access your data, to have mistakes corrected, to have data erased in some cases, to restrict or object to processing, to receive your data in a portable format and to withdraw consent. To use any of these rights, write to [email protected]. We reply within one month. If you are unhappy with how we use your data you can complain to the Information Commissioner's Office.
Service providers
We use outside companies to host the site, send email, verify identity, process payments and provide customer support tools. They may only use your data to provide those services to us.
Analytics
With your consent we may use analytics tools to measure which pages are useful and where visitors leave. Reports are based on aggregated or pseudonymised data and are used to improve the site.
Advertising and retargeting
If you agree, advertising technologies may be used to show you our adverts on other sites, and to measure whether those adverts work. You can withdraw consent in the cookie settings or in your browser or device advertising settings.
Links to third-party sites
This policy does not cover other websites that we link to. Please read their privacy notices before you give them personal data.
Children's privacy
Our services are for adults aged 18 and over. We do not knowingly collect data about children, and if we learn that we have, we will delete it.
Changes to this policy
We may update this policy from time to time. The current version is always on this page, and if a change is significant we will notify registered users by email.
Contact us
If you have questions about privacy or want to exercise your rights, email [email protected] or write to us at 22 Bishopsgate, London EC2N 4BQ, United Kingdom.