Introduction
Acorn 2 Oak FX is owned by Earnex Global Group LLC and takes the privacy of your information very seriously. This policy together with our Terms of Use and Terms of Sales explains how and for what purposes we use the information collected about you via acorn2oak-fx.com (referred to below as the “Site”).
Please read this privacy policy carefully. By using the Site and any products and/or services we offer via the Site, you are agreeing to be bound by this policy in respect of the information collected about you via this Site.
You have certain rights in relation to your data, including the right to object to processing based on legitimate interests, profiling (including the use of custom and lookalike/similar audiences), and direct marketing. At any time, you can exercise your rights by emailing us at [email protected]
For further details about our processing and your rights, please see below.
Disclaimer
We maintain commercial relationships with our Service Providers. This means that we may receive payment when we share information that you provide to us via our webforms with our Service Provider(s) in order to allow them to offer you a quote or information for the product or service that you have requested.
About Our Site
Our site enables people to request quotes or information for the product or service shown or selected on this site (the “Product”).
The service that our site provides is to connect people who are looking to purchase the Product with relevant providers of the Product (“Service Providers”).
If you’d like to request and receive quotes or information for the Product (“Quotes”), please complete and submit our webform.
Once we’ve received your request, we’ll connect you with one or more relevant Service Providers. We’ll tell the Service Providers who you are, and your Product requirements, and they’ll then contact you directly with your requested Quotes.
For certain products, before connecting you with relevant Service Providers, we may call you to confirm your details or requirements.
You’ll see on our webform that we have a really clear consent statement. This statement sets out the Service Providers that will contact you.
You can choose which Service Provider to buy from. But you don’t have to buy from any of them. There’s no obligation to purchase.
We don’t work with any Service Providers until we have a legal contract in place. This is to ensure that they respect your data and rights by keeping your data secure and confidential, limiting their use of your data (i.e. to providing you with the requested Quotes), and not sharing your data with anyone else.
About Us
Acorn 2 Oak FX is owned by Earnex Global Group LLC (“we”, “us”, “our”) Earnex Global Group LLC is registered by the Financial Services Authority (FSA) of St. Vincent and the Grenadines – Registration No. 2553 LLC 2022. Registered Address Hinds Building, Kingstown, Saint Vincent and the Grenadines
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
► Identity Data includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
► Financial Data includes: bank account; source of funds, source of wealth; payment card details.
► Transaction Data includes: details about payments to and from you and other details of products and transactions you have placed via our services and/or products.
► Technical Data includes: internet protocol (IP) address (for FIX connections and ClearVision tools), your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
► Profile Data includes: your username and password, transactions or orders made by you, your interests, preferences, feedback and survey responses.
► Usage Data includes: information about how you use our products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature/ product or service we provide.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How We Use Your Personal Data
We will only use your personal data where the law allows. Most commonly, we will use your personal data in the following circumstances:
► Where we need to perform the contract we are about to enter into or have entered into with you.
► Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
► Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the Compliance Department.
Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purposes for which we use them.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Transferring Your Data
We share your personal data within the Earnex Financial Group and with international service providers. This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data as set out in this policy.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguard is implemented:
► Where we use certain service providers, we may use specific contracts based on the contents of this notice
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Compliance Department if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/ Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register as a new client | – Identity documentation – Contact details |
– Performance of a contract with you – Necessary to comply with regulatory obligations |
| To process and deliver your order including: – Managing payments, fees, charges and collect monies owed to us |
– Identity documentation – Contact details – Financial information – Transaction details |
– Performance of a contract with you – Necessary for our legitimate interests |
| To manage our relationship with you which will include: – Notifying you about changes to our terms |
– Identity documentation – Contact details |
– Performance of a contract with you – Necessary to comply with regulatory obligations – Necessary for our legitimate interests |
| To administer and protect our business | – Identity documentation – Contact details |
– Necessary to comply with regulatory obligations – Necessary for our legitimate interests |
| To use data analytics to improve our products/services, customer relationships and experiences |
– Technical – Usage |
– Necessary for our legitimate interests |
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
► Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
► Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
► Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
► Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate rounds to process your information which override your rights and freedoms.
► Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
► Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
► Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the Compliance Department.
Contacting Us
If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at [email protected].
