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Privacy Policy

Associated Foreign Exchange Limited ("We") are committed to protecting and respecting your privacy

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Associated Foreign Exchange Limited of 5th Floor, 129 Wilton Road, London SW1V 1JZ.

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Information we collect from you

We may collect and process the following data about you:

Information that you provide by filling in forms on our site [insert domain address] (our site). This includes information provided at the time of registering to use AFEXDirect, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.

If you contact us, we may keep a record of that correspondence.

We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

Details of transactions you carry out through our site and of the fulfilment of your orders.

Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Details of scoring used to assess an application and information used to verify your identity

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IP addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

To estimate our audience size and usage pattern.

To store information about your preferences, and so allow us to customise our site according to your individual interests.

To speed up your searches.

To recognise you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

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Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the "EEA") especially to the United States. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Secure Socket Link encryption. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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Uses made of the information

We use information held about you in the following ways:

To ensure that content from our site is presented in the most effective manner for you and for your computer.

To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

To carry out our obligations arising from any contracts entered into between you and us.

To allow you to participate in interactive features of our service, when you choose to do so.

To notify you about changes to our service.

If you are an existing customer, we will contact you by post, telephone and/or electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.

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Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our parent company or our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985.

We may disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

If Associated Foreign Exchange Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of terms and conditions and other agreements; or to protect the rights, property, or safety of Associated Foreign Exchange Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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Your rights

YOUR RIGHTS You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting the Compliance Officer at Associated Foreign Exchange Limited of 5th Floor, 129 Wilton Road, London SW1V 1JZ.

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Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

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Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

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Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Compliance Officer at Associated Foreign Exchange Limited of 5th Floor, 129 Wilton Road, London SW1V 1JZ.

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Complaint and redress procedure

We are committed to resolving your complaint fairly and quickly. In most cases this can be done if you contact us as soon as possible. We will try to resolve your complaint by listening to your concerns and agreeing a solution with you. If you have a complaint about any aspect of our service you can contact us in writing, by email or by telephone.

To make a complaint, please contact your Account Executive, or if you feel it is more appropriate, the UK Regional Manager at:

129 Wilton Road
Fifth Floor
London
SW1V 1JZ
England

Email: complaints.uk@afex.com
Tel: ++44 (0)870 735 8484
Tel: ++44 (0)207 811 6500
Fax: ++44 (0)207 811 6599

Please provide the following information:

To help us investigate and resolve your complaint as quickly as possible, please provide the following information:

• your name and address
• a clear description of your concern or complaint
• details of what you would like us to do to resolve the complaint
• copies of any relevant documents/information
• a daytime telephone number where we can contact you
• any times you would prefer us to contact you

If you are not happy with our response:

If you are not satisfied with our suggested resolution, or if eight weeks have passed since you first brought your complaint to our attention, you have the right to refer your complaint to the Financial Ombudsman Service. If you want the Financial Ombudsman Service to look into your complaint, you must contact them within six months of the date of any final response issued.

You can write to them at:

The Financial Ombudsmen Service
South Quay Plaza
183 Marsh Wall
London
E14 9SR

Email: complaint.info@financial-ombudsman.org.uk

Alternatively, you can phone 0845 080 1800. Further helpful information can be obtained from visiting the Financial Ombudsman web site at www.financial-ombudsman.org.uk.The Financial Ombudsman Service offers a free independent service and they can help with most financial complaints. However, there are some limitations on what the Financial Ombudsman Service can look into, and further information about this can be obtained from them directly.

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New payment services regulations

We are pleased to announce that as of November 1 2009, AFEX is authorised and regulated by the Financial Services Authority for the provision of payment services as a Payment Institution.

The Payment Services Regulations govern how we provide payment services where both the payer and the payee are located within the European Economic Area.

We will be required to safeguard client funds we hold in relation to an electronic payment.

We will also have to meet criteria set by the FSA in terms of corporate governance, solvency and risk identification and management.

View the FSA register.