Privacy | Alpha Group

Privacy Policy

Alpha FX Limited and Alpha FX Europe Limited (“we”, “us”, or “our”) recognise and value the trust that you place in us when interacting with us. This privacy policy (the “Privacy Policy”) explains how we use your Personal Data, as defined in section 2 below, describes the categories of Personal Data we process and for what purposes and explains your data protection rights and how to exercise them.

As Alpha FX Limited is established in the United Kingdom (“UK”) but operates as a global business, it is subject to (i) the UK General Data Protection Regulation, as supplemented by the Data Protection Act 2018 and (ii) the EU General Data Protection Regulation. Alpha FX Europe Limited is subject to the EU General Data Protection Regulation and the relevant data protection legislation applicable in Malta.

We take your privacy seriously and we are committed to collecting and using your Personal Data fairly and in accordance with the requirements of applicable data protection legislation.

1. Important information and who we are

Depending on the Alpha entity you are facing, Alpha FX Limited or Alpha FX Europe Limited will be the data controller of, and will be responsible for, your Personal Data.

Alpha FX Limited is a private limited company incorporated under the laws of England and Wales, with its registered office at Brunel Building, 2 Canalside Walk, London, W2 1DG. Alpha FX Limited is authorised and regulated in the UK by the Financial Conduct Authority.
Alpha FX Europe Limited is a limited liability private exempt company incorporated under the laws of Malta, with its registered office at 171, Old Bakery Street, Valletta VLT 1455, Malta. Alpha FX Europe Limited is authorised and regulated in Malta by the Malta Financial Services Authority.

If you have any questions about this Privacy Policy or our data protection practices, please contact us by emailing GDPR@alphafx.co.uk or by courier at the appropriate postal address above.

2. The data we collect about you

«Personal Data” means any information relating to an identified or identifiable natural person. We may collect, use, store, transfer or otherwise process different kinds of Personal Data about you, as follows:

Identity data including your name, date of birth, place of birth, gender, nationality, copies of your identity card, passport and/or driving licence, and, where offered to us, data relating to your family, education and employment background.
Contact data including your billing/registered/residential address, email address and telephone number.
Client-related data including business information, relationship with you (or with a client of whom you are an employee or other staff member), information about any shareholdings, business contact details.
Financial data including your bank account details, your tax status information, your tax identification number and your fiscal residence.
Other background identification data including evidence of beneficial ownership and source of funds to comply with our client due diligence, know your customer (“KYC”) and anti-money laundering regulations and collected as part of our client acceptance and ongoing monitoring procedures as required by law.
Usage data including data obtained through your use of our website or any electronic system or interface that we provide to you through our website (the “Online Platform”) as well as data collected through cookies, server logs and other similar tracking technologies.

We may process your special category personal data if:

we have your explicit consent; or
the processing is necessary for reasons of substantial public interest, on the basis of UK law or Union or Member State law, for example to comply with KYC and anti-money laundering regulations.

We may collect data relating to criminal convictions and offences subject to compliance with the strict conditions set out under the applicable data protection legislation.

We digitally record all telephone conversations.

3. How is your personal data collected?

We use different methods to collect Personal Data from and about you including through:

direct interactions with you. In those cases, it is your responsibility to ensure that all such Personal Data is complete in all material respects and not misleading;
publications/databases made available by official authorities;
our corporate clients, prospects, or service providers;
websites/social media pages containing information made public by you (e.g. your own website or social media);
databases made publicly available by third parties; and
automated technologies or interactions, for example through your use of our website or Online Platform. We collect this Personal Data by using cookies, server logs and other similar tracking technologies. Please see our Cookie Policy for further details.

We may also collect information about you even if you do not have a direct relationship with us. This may for example happen when your contact details are provided to us by one of our clients, prospects and if you are (by way of example and without limitation) a legal representative, an ultimate beneficial owner, a shareholder, an employee or a staff member of that client or prospect.

4. How we use your personal data

We will only use your Personal Data for the following purposes:

To provide foreign exchange services, payment services and related services to you (or to a client of whom you are an employee or other staff member), which includes providing you with information regarding our services, assisting you and answering your requests and having proof of transactions;
to discharge our legal and regulatory obligations, e.g. to prevent and respond to actual or potential fraud or illegal activities according to KYC and anti-money laundering regulations ;
to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
to record and monitor your use of our website, or our Online Platform or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
in the event that we buy or sell any business or assets, or substantially all of our assets are acquired by a third party, we may share your Personal Data to the prospective buyer, and in the event of an acquisition, Personal Data held by us about our clients will be one of the transferred assets;
to engage in marketing and business development activity in relation to our services, including to undertake business/market research, survey and analysis;
for managing the operation of our website, our Online Platform and our business;
to look into any complaints or queries you may have.

In addition, we will only process your Personal Data where we have a lawful basis for doing so. Our lawful basis will be one or more of the following:

Consent – insofar as you have given us your consent for the processing of Personal Data, such consent will serve as a legal basis for the processing; You can withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. I Where we are also processing your Personal Data based on a different legal basis – to perform a contract, for example – your withdrawal of consent will not affect that additional processing.
Performance of a contract or processing of a payment instruction – we may need to collect and use your Personal Data for the performance of a contract to which you are party or in order to take steps at your request prior to entering a contract or to process a payment instruction from you.
Legitimate interests – we may use your Personal Data as is necessary for the purposes of pursuing our legitimate interests (this includes carrying out the business of providing foreign exchange services, payment services and related services and pursuing our general business interests) where your interests and fundamental rights do not override those interests.
Compliance with our legal obligations – we may use your Personal Data as necessary to comply with applicable law and regulations, including to comply with our client due diligence, KYC and anti-money laundering regulations.

Where we need to collect, or you are required to provide, Personal Data by law or applicable regulations or under the terms of a contract we have with you and you fail to provide the Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the Personal Data is collected.

5. Disclosures of your personal data

In providing services to our clients and in complying with our legal obligations, we may share your Personal Data, insofar as we are permitted by applicable data protection legislation to do so, with the following recipients:

third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Data for the purposes described in this Privacy Policy. This may include, but is not limited to, IT service providers such as cloud providers of software as a service, data room providers and providers of our IT servers and communications service providers; and our professional advisors (legal, auditing or other special services provided by lawyers, notaries, trustees, company auditors or other professional advisors);
third parties relevant to the services that we provide. This may include, but is not limited to, counterparties to transactions, other professional service providers, financial institutions, regulators, authorities, governmental institutions and stock exchanges; and/or
to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation.

The recipients referred to above may be located outside the jurisdiction in which you are located or in which Alpha provides the services. See the section on “Sending Personal Data outside the UK and the EEA” below for more information.

6. Sending personal data outside the UK and the EEA

We may need to transfer your Personal Data to a country outside the UK or outside the European Economic Area (the “EEA”), such country being referred to as a “third country”.

Where this is the case, we will make sure that your Personal Data is protected to the same extent as in the UK and the EEA by implementing one of the following measures:

we will transfer Personal Data to a third country with privacy laws that give the same level of data protection as in the UK and EEA, as evidenced by (i) “adequacy regulations” made by the Secretary of State (in case of a transfer outside the UK) or (ii) an “adequacy decision” adopted by the European Commission (in case of a transfer outside the EEA);
in the absence of adequacy regulations or of an adequacy decision (as applicable), we will put in place appropriate safeguards such as (i) standard contracts for international transfers of Personal Data approved for use by the UK Information Commissioner’s Office (in case of a transfer outside the UK) or (ii) standard contractual clauses approved for use by the European Commission (in case of a transfer outside the EEA).

7. Personal data retention

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your Personal Data for a longer period (i) to comply with our record retention requirements under applicable law and regulations, (ii) to defend or bring any existing or potential legal claims, (iii) to deal with any future complaints regarding the services we provided and (iv) to maintain business records for analysis and/or audit purposes.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. Your legal rights

In accordance with the applicable data protection legislation, and within the limits thereof, you have, in relation to your Personal Data, the following rights:

Right of access: you can ask us to provide you with a copy of the Personal Data that we hold about you.
Right to rectification: if you believe any of your Personal Data is incorrect or incomplete, we will, upon your request, take steps to check it and correct any factual inaccuracies.
Right to erasure: you can ask us to delete, remove, or stop using your Personal Data if there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below)..
Right to restriction of processing: under certain circumstances, you may ask us to restrict the processing of your Personal Data.
Right to object to processing: under certain circumstance, you can object to us keeping or using your Personal Data.
Right to data portability: if we hold your Personal Data electronically, you can ask us to transfer the data to another organisation in a safe and secure way and in a machine readable format.

If you wish to exercise any of the rights set out above, , or you wish to withdraw your consent to our processing of your Personal Data, please contact us by emailing GDPR@alphafx.co.uk

We are committed to working with you to achieve a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right:

in relation to Alpha FX Limited: to make a complaint at any time to the Information Commissioner’s Office, the UK data protection authority (www.ico.org.uk);
in relation to Alpha FX Europe Limited: to make a complaint at any time to the Office of the Information and Data Protection Commissioner, the Maltese data protection authority (https://idpc.org.mt/) or to your national Data Protection Authority, if you are located in the EEA (Our Members | European Data Protection Board (europa.eu)).

9. Cookies

We may use cookies and other similar tracking technologies on our website and Online Platform. Cookies are small text files that may be stored on your computer or mobile device when you visit a website. These technologies may do different things, such as letting you navigate between web pages efficiently and remembering your preferences. To find out more about how we use cookies and email tracking, please see our Cookie Policy.

10. How is this Privacy Policy modified?

This Privacy Policy may change from time to time, and we shall take all reasonable steps to inform you in such a case, in particular by publication on our website, which we encourage you to consult regularly.

Australia Privacy Policy

Alpha FX Limited (“we”, “us”, or “our”) recognise and value the trust that you place in us when interacting with us. This privacy policy (the “Privacy Policy”) explains how we use your Personal Information (as defined in section 2 below) and comply with our obligations under the Privacy Act 1988 (Cth) («the Privacy Act»), describes the categories of Personal Information we process and for what purposes and explains your rights under the Privacy Act and how to exercise them.

We take your privacy seriously and we are committed to collecting and using your Personal Information fairly and in accordance with the requirements of the Privacy Act.

1. Important information and who we are

Alpha FX Limited is a private limited company incorporated in England and Wales, with UK company number 05108142 and ABN 68 654 957 258 and whose registered office is at Brunel Building, 2 Canalside Walk, London, W2 1DG.

If you have any questions about this Privacy Policy or our privacy practices, please contact us by emailing GDPR@alphafx.co.uk or by courier at the appropriate postal address above.

2. The data we collect about you

“Personal Information” means any information or opinion about an identified or reasonably identifiable individual. We may collect, use, store, transfer or otherwise process different kinds of Personal Information about you, as follows:

Identity data including your name, date of birth, place of birth, gender, nationality, copies of your passport and/or driving licence, and, where offered to us, data relating to your family, education and employment background.
Contact data including your billing/registered/residential address, email address and telephone number.
Client-related data including business information, relationship with you (or with a client of whom you are an employee or other staff member), information about any shareholdings, business contact details.
Financial data including your bank account details, your tax status information, your tax identification number and your fiscal residence.
Other background identification data including evidence of beneficial ownership and source of funds to comply with our client due diligence, know your customer (“KYC”) and anti-money laundering regulations and collected as part of our client acceptance and ongoing monitoring procedures as required by law.
Usage data including data obtained through your use of our website or any electronic system or interface that we provide to you through our website (the “Online Platform”) as well as data collected through cookies, server logs and other similar tracking technologies.
Any other Personal Information that may be required in order to facilitate your dealings with us.

3. How is your personal information collected?

We may collect data relating to criminal convictions and offences subject to compliance with applicable legislation.

We use different methods to collect Personal Information from and about you including through:

direct interactions with you. In those cases, it is your responsibility to ensure that all such Personal Information is complete in all material respects and not misleading;
publications/databases made available by official authorities;
our corporate clients, prospects, or service providers;
websites/social media pages containing information made public by you (e.g. your own website or social media);
databases made publicly available by third parties; and
automated technologies or interactions, for example through your use of our website or Online Platform. We collect this Personal Information by using cookies, server logs and other similar tracking technologies. Please see our Cookie Policy for further details.

4. How we use your personal information

We may collect, hold, use and disclose your Personal Information for the following purposes:

to provide foreign exchange services and related services to you (or to a client of whom you are an employee or other staff member), which includes providing you with information regarding our services, assisting you and answering your requests and having proof of transactions;
to discharge our legal and regulatory obligations, e.g. to prevent and respond to actual or potential fraud or illegal activities according to KYC and anti-money laundering regulations;
to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
to record and monitor your use of our website, or our Online Platform or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
in the event that we buy or sell any business or assets, or substantially all of our assets are acquired by a third party, we may share your Personal Information to the prospective buyer, and in the event of an acquisition, Personal Information held by us about our clients will be one of the transferred assets;
to engage in marketing and business development activity in relation to our services, including to undertake business/market research, survey and analysis, and to send you marketing and promotional messages;
for managing the operation of our website, our Online Platform and our business; and/or
to look into any complaints or queries you may have.

Where we need to collect, or you are required by law or contract to provide, Personal Information, and you fail to provide the Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to decline to provide or receive the relevant services.

5. Disclosures of your personal information

In providing services to our clients and in complying with our legal obligations, we may, for the purposes described in this Privacy Policy, disclose your Personal Information (insofar as we are permitted by the Privacy Act to do so) with the following recipients:

third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Information. This may include, but is not limited to, IT service providers such as cloud providers of software as a service, data room providers and providers of our IT servers and communications service providers; and our professional advisors (legal, auditing or other special services provided by lawyers, notaries, trustees, company auditors or other professional advisors);
third parties relevant to the services that we provide. This may include, but is not limited to, counterparties to transactions, other professional service providers, financial institutions, regulators, authorities, governmental institutions, stock exchanges, and members of our group; and/or
to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (for example, to government agencies, regulatory bodies and law enforcement agencies).

The recipients referred to above may be located outside the jurisdiction in which you are located or in which Alpha provides the services. See the section on “Sending Personal Information outside Australia” below for more information.

6. Sending personal information outside of Australia

To operate our business, we may need to transfer your Personal Information outside of Australia.

When you provide your Personal Information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that Personal Information in compliance with Australian privacy law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such Personal Information in a way that is consistent with the Privacy Act.

7. Direct marketing?

We may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

8. Your legal rights

In accordance with the Privacy Act, and within the limits thereof, you have, in relation to your Personal Information, the following rights:

Right of access: you can ask us to provide you with a copy of the Personal Information that we hold about you, by contacting us using the information at the end of this Policy. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
Right to rectification: if you believe any of your Personal Information is incorrect or incomplete, we will, upon your request, take reasonable steps to check it and correct any factual inaccuracies.

If you wish to exercise either of the rights set out above, you can contact us using the details at the end of this Policy.

9. Complaints

If you believe that we have breached any privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the details at the end of this Policy.

We are committed to working with you to achieve a fair resolution of any complaint or concern about your privacy. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

10. Cookies

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC). For further information regarding how to make a complaint to the OAIC, you can visit Privacy complaints – Home (oaic.gov.au), or phone 1300 363 992.

Privacy Policy

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. Sending personal data outside the UK and the EEA

7. Personal data retention

8. Your legal rights

9. Cookies

10. How is this Privacy Policy modified?

Australia Privacy Policy

1. Important information and who we are

2. The data we collect about you

3. How is your personal information collected?

4. How we use your personal information

5. Disclosures of your personal information

6. Sending personal information outside of Australia

7. Direct marketing?

8. Your legal rights

9. Complaints

10. Cookies

11. How is the privacy policy modified?