DATA PROTECTION & COMPLIANCE

Privacy Policy FxRex.pro

This comprehensive Privacy Policy outlines how FxRex.pro collects, processes, stores, and protects your personal data in compliance with international data protection regulations and financial industry standards.

Last Updated: November 15, 2024 | Version: 2.1

1 Introduction & Scope

FxRex.pro ("we," "our," "us") operates the forex trading platform and related services accessible via https://fxrex.pro. We are committed to protecting your privacy and handling your personal data with transparency and security.

Scope of Application

This Privacy Policy applies to all personal data collected through our website, mobile applications, API integrations, customer support channels, marketing activities, and any interaction with our services globally.

1.1. Legal Framework & Compliance

Our data processing activities comply with:

  • General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679
  • California Consumer Privacy Act (CCPA) and CPRA
  • UK Data Protection Act 2018 and UK GDPR
  • Financial Conduct Authority (FCA) data protection requirements
  • Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations
  • Other applicable national and international data protection laws

2 Data Controller Information

Data Controller Details

Legal Entity
FxRex.pro Ltd.
Registered in England and Wales
Company Number: 14528743
VAT Number: GB 425 6789 01
Registered Office
International Business Centre
Level 5, 123 Finance Street
London, EC2A 4NE
United Kingdom
Data Protection Officer
Mr. Alexander Reed
Email: dpo@fxrex.pro
Phone: +44 20 7946 0958 (DPO line)

2.1. Joint Controllers & Representatives

In certain processing activities, we act as joint controllers with our partner brokers. We have established clear agreements outlining respective responsibilities in compliance with GDPR Article 26.

EU Representative

For GDPR compliance, our EU representative is:
DataProtect EU GmbH
Friedrichstraße 95, 10117 Berlin, Germany
Email: eu-representative@fxrex.pro

3 Definitions & Key Terms

Personal Data
Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly.
Processing
Any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, erasure, or destruction.
Special Category Data
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
Consent
Freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data.
Legitimate Interest
The interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience.

4 Detailed Data Collection Categories

4.1. Registration & Account Data

Data Category Specific Elements Purpose Legal Basis
Identity Information Full name, date of birth, nationality, photograph Account creation, KYC verification Contract, Legal obligation
Contact Details Email, phone, address, emergency contact Communication, service delivery Contract
Financial Information Bank accounts, payment cards, tax ID, source of funds Transaction processing, AML compliance Contract, Legal obligation
Employment Information Occupation, employer, annual income, net worth Suitability assessment, risk profiling Legal obligation (MiFID II)

4.2. Trading & Transaction Data

  • Trading Activity: Positions opened/closed, instruments traded, order history, execution prices
  • Account Performance: Balance, equity, margin, profit/loss, drawdown statistics
  • Platform Usage: Login times, session duration, features used, click patterns
  • Technical Data: IP addresses, device fingerprints, browser details, operating system
  • Communication Records: Support tickets, chat logs, email correspondence, call recordings

4.3. Automated & Derived Data

We generate and process derived data including:

  • Risk Profile: Calculated risk score based on trading behavior
  • Trading Patterns: Analysis of trading strategies and preferences
  • Market Analysis: Correlation of your activity with market conditions
  • Predictive Analytics: Models to personalize services and detect anomalies

Sensitive Data Notice

We do not intentionally collect Special Category Data unless required by law (e.g., politically exposed persons screening). If such data is inadvertently collected, it is processed with enhanced protections.

5 Purposes & Legal Bases for Processing

5.1. Primary Purposes

Processing Purpose Data Categories Legal Basis Retention Period
Account Management Identity, Contact, Profile Contract (Art. 6(1)(b) GDPR) 7 years post-closure
KYC/AML Compliance Identity, Financial, Employment Legal obligation (Art. 6(1)(c)) 10 years (regulatory)
Trade Execution Trading, Financial, Technical Contract, Legal obligation 7 years
Risk Management Trading, Financial, Derived Legitimate interest (Art. 6(1)(f)) 5 years
Marketing & Analytics Usage, Profile, Technical Consent (Art. 6(1)(a)) 3 years post-consent
Fraud Prevention All categories as needed Legitimate interest, Legal obligation 7 years

5.2. Legitimate Interests Assessment

Where we rely on legitimate interests, we have conducted a Legitimate Interests Assessment (LIA) considering:

  • Purpose test: Is there a legitimate interest behind the processing?
  • Necessity test: Is the processing necessary for that purpose?
  • Balancing test: Do our interests override your interests or fundamental rights?

Examples of Legitimate Interests

• Fraud prevention and network security
• Direct marketing (with opt-out rights)
• Reporting criminal acts to authorities
• Internal administrative purposes
• Service improvement and innovation

6 Data Sharing & International Transfers

6.1. Categories of Recipients

Recipient Category Purpose of Sharing Data Shared Safeguards
Partner Brokers Account opening, trade execution Identity, Financial, KYC Data Processing Agreements
Payment Processors Deposit/withdrawal processing Financial, Contact PCI-DSS compliance
Cloud Providers Data hosting, infrastructure All data (encrypted) ISO 27001, SCCs
Analytics Providers Service improvement, analytics Anonymized, aggregated Data minimization
Regulatory Authorities Legal compliance, investigations As required by law Legal obligation

6.2. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including:

  • United Kingdom: Adequacy decision from EU Commission
  • United States: Using Standard Contractual Clauses (SCCs)
  • Other jurisdictions: With appropriate safeguards as per GDPR Chapter V

Transfer Mechanisms

We use GDPR-approved transfer mechanisms including:
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules (BCRs)
• Derogations for specific situations (e.g., explicit consent)
• UK International Data Transfer Agreement (IDTA)

6.3. Sub-processors

We maintain an updated list of sub-processors available upon request. Key sub-processors include:

  • AWS - Cloud infrastructure (USA/Ireland)
  • Stripe - Payment processing (USA)
  • Twilio - Communications (USA)
  • Google Analytics - Web analytics (USA)
  • Intercom - Customer support (USA)

7 Data Security & Protection Measures

7.1. Technical Security Measures

  • Encryption: AES-256 encryption at rest, TLS 1.3+ for data in transit
  • Access Controls: Role-based access, multi-factor authentication, privileged access management
  • Network Security: Next-generation firewalls, DDoS protection, intrusion detection/prevention systems
  • Endpoint Security: Device encryption, mobile device management, endpoint detection and response
  • Application Security: Secure SDLC, vulnerability scanning, penetration testing, code reviews

7.2. Organisational Security Measures

  • Security Policies: Comprehensive information security management system (ISMS)
  • Employee Training: Annual security awareness training, phishing simulations
  • Incident Response: Documented incident response plan, regular drills
  • Business Continuity: Disaster recovery plans, regular backups, redundancy
  • Third-party Risk Management: Vendor security assessments, contractual obligations

Security Certifications

Our security practices align with:
• ISO 27001:2022 Information Security Management
• SOC 2 Type II compliance
• PCI DSS Level 1 for payment processing
• NIST Cybersecurity Framework

7.3. Data Breach Response

In the event of a personal data breach, we will:

  • Notify the supervisory authority within 72 hours where required
  • Communicate with affected individuals without undue delay
  • Document all breaches, regardless of notification requirement
  • Take immediate steps to contain and remediate the breach
  • Conduct post-incident review and implement improvements

8 Data Retention & Deletion Policy

8.1. Retention Schedule

Data Category Retention Period Legal/Regulatory Basis Deletion Method
Account Registration Data 7 years after account closure FCA record-keeping requirements Secure erasure
Financial Transactions 10 years after transaction Money Laundering Regulations Secure erasure
KYC/AML Documents 10 years after relationship ends 5MLD, JMLSG Guidance Physical destruction/Secure deletion
Marketing Data 3 years after last interaction GDPR principle of storage limitation Anonymization
Support Communications 6 years after resolution Limitation Act 1980 Secure erasure
System Logs 1 year Operational necessity Automated deletion

8.2. Data Minimization & Storage Limitation

We adhere to the principles of data minimization and storage limitation by:

  • Collecting only data necessary for specified purposes
  • Regularly reviewing retained data for continued necessity
  • Anonymizing data where possible for statistical purposes
  • Implementing automated data lifecycle management
  • Conducting annual data retention audits

Right to Deletion Exception

Your right to erasure may be limited where we have legal obligations to retain data (e.g., financial regulations, tax laws, legal proceedings). In such cases, we will restrict processing instead of deletion.

9 Your Data Protection Rights

9.1. Comprehensive Rights Overview

Right of Access

Article 15 GDPR

Obtain confirmation of processing and access to your personal data.

Right to Rectification

Article 16 GDPR

Request correction of inaccurate or incomplete personal data.

Right to Erasure

Article 17 GDPR

Request deletion of personal data under specific conditions.

Right to Restrict

Article 18 GDPR

Request restriction of processing in certain circumstances.

Data Portability

Article 20 GDPR

Receive your data in structured, commonly used format.

Right to Object

Article 21 GDPR

Object to processing based on legitimate interests.

9.2. How to Exercise Your Rights

To exercise your rights, please:

  1. Submit a verifiable request via our Data Subject Request Portal
  2. Email us at privacy@fxrex.pro
  3. Contact our DPO directly at dpo@fxrex.pro

Response Timeline

We respond to all valid requests within 30 calendar days. Complex requests may take up to 90 days, but we will inform you within 30 days if an extension is needed.

9.3. Identity Verification

To protect your data, we verify your identity before processing rights requests. We may request:

  • Government-issued photo ID
  • Recent proof of address
  • Account-specific verification questions
  • Two-factor authentication confirmation

10 Cookies & Tracking Technologies

10.1. Detailed Cookie Classification

Cookie Category Purpose Examples Duration Essential
Strictly Necessary Website functionality, security Session cookies, CSRF tokens Session Yes
Performance Analytics, performance monitoring Google Analytics, Hotjar 2 years No
Functional Remember preferences Language, theme settings 1 year No
Targeting/Advertising Personalized advertising Facebook Pixel, Google Ads 2 years No

10.2. Cookie Management

You can manage cookies through:

Consent Management

We use a consent management platform that records your preferences, provides granular control, and automatically renews consent requests annually or when purposes change significantly.

11 Children's Privacy

Our services are not directed to individuals under the age of 18 ("minors"). We do not knowingly collect personal data from minors.

Age Verification

During registration, we verify age through date of birth confirmation and may request additional verification if age is in question. If we learn that we have collected personal data from a minor, we will take steps to delete that information promptly.

11.1. Parental Controls

Parents or guardians who believe their child has provided us with personal data may contact us to request deletion. We will require verification of parental relationship before processing such requests.

12 Policy Updates & Contact Information

12.1. Policy Version History

Version 2.1
November 15, 2024

• Added detailed data processing purposes table
• Enhanced security measures description
• Updated international transfer mechanisms
• Expanded user rights section with practical guidance

Version 2.0
August 1, 2024

• Comprehensive GDPR compliance updates
• Added Data Processing Agreement references
• Enhanced data subject rights procedures
• Updated contact information and DPO details

12.2. Notification of Changes

We will notify you of material changes to this Privacy Policy by:

  • Email notification to registered users 30 days before changes take effect
  • Prominent notice on our website for 30 days
  • In-app notifications for active users
  • Updated "Last Updated" date on this page

12.3. Contact Information

General Privacy Inquiries
Email: privacy@fxrex.pro
Response time: 5 business days
Supervisory Authority (UK)
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: ico.org.uk | Phone: 0303 123 1113

Questions About This Policy?

We are committed to transparency about our data practices. If you have questions not covered here, please contact our Data Protection Officer.

Contact DPO