This document is published to state the Privacy and Cookies Policy (“P&C Policy”) for www.myforexreviews.com (“Website”) and forms an integral part of the Website’s Terms and Conditions. All users (“User” or “Users”) of the Website should carefully read this P&C Policy as it relates to their legal rights in respect of their personal information and privacy. By using the Website or continuing to use it, the User expressly agrees to be legally bound by this P&C Policy.
This P&C Policy is intended to give User’s information on the obligations of the owner of the Website (“Website Owner”) and on the rights of Users in relation to their personal information and privacy as regards:
- the collection of information;
- use of the information collected;
- how information is processed and used;
- with whom the information is shared and on what basis;
- rights of Users in relation to information; and
- how the information collected is stored and secured.
BY USING THE WEBSITE, USERS EXPRESSLY AGREE TO THE P&C POLICY STATED HEREIN BY THE WEBSITE OWNERWITHOUT ANY RESERVATION. IF YOU DO NOT ACCEPT ANY PART OF THE P&C POLICY YOU MUST IMMEDIATELY CEASE TO USE THE WEBSITE.
THW WEBSITE OWNER RESERVES THE RIGHT TO MAKE CHANGES TO THIS P&C POLICY AT ITS DISCRETION WITHOUT REFERENCE TO USER. IF THE USER IS UNHAPPY WITH ANY FUTURE CHANGES, THE USER MUST IMMEDIATELY CEASE TO USE THE WEBSITE. ANY CONTINUED USAGE FO THE WEBSITE SHALL BE DEEMED ANY ACCETPTANCE ANY SUCH FUTURE CHANGES.
This P&C Policy is directed to all Users equally and the primary privacy requirements that the Website Owner complies with is the Data Protection Act 2018 of the United Kingdom. As the Website Owner has client’s resident in the European Union (“EU”)/European Economic Area (“EEA”) and in the USA, this P&C Policy complies with GDPR and CCPA requirements in addition to United Kingdom requirements. As a whole. this P&C Policy applies to all Users.
In this P&C Policy, unless there is something in the subject matter or context inconsistent therewith, the following terms and expressions will have the following meanings:
California Consumer Privacy Act of 2018
Without exception, all images, text, information, data, audio, videos, graphics, articles, blogs, computer code, software, algorithms, business models, and any other material provided or posted by the Website Owner on or through the Website, including the Products and Services.
Cookies are tiny files which contain slivers of data and information, which may or may not include, an anonymous unique identifier in relation to whom the cookie is directed. It is a tiny file that a website transfers and stores on your device with the purpose of tracking your movements within the Website, remembering your preferences and your interaction with the various components and features of the Website.
Data Protection Act 2018
Regulation (EU) 2016/679 General Data Protection Regulation.
“Products and Services”
Products and Services made available for subscription, sale or right to use on the Website by the Website Owner.
“Terms and Conditions”
“User” or “Users” or “You”
Any persons and/or entities that use the Website and shall for all purposes include Members and Traders.
www.myforexreviews.com, which is owned, developed and operated by the Website Owner and includes all the Content and the domain name.
2.1 DPA and GDPR regulations require that the Website Owner must have a demonstrable legal basis for the collection and processing of personal information and data on Users. The Website Owner does not require Users to submit any personal information to use the Website as no registration is required to have full access to the Content. The Website is operated on a ‘free to use’ ‘as is’ basis. The only personal information collected on Users by the Website Owner is:
(a) their email address if Users voluntarily elect to receive updates on the Website, including new reviews on Brokers, and promotions from Brokers and other third parties. Users are able deregister their email at any time without incurring any penalty or reduction is service or access;
(b) initiate contact with the Website Owner for any reason. In such cases, the name and the email of the User initiating contact is recorded to meet legal obligations of proper record keeping.
2.2 The only non-User initiated information collected on Users is on their usage of the Website and the Content and such information is collected exclusively on an anonymous basis.
2.3 The anonymous information on Users is collected on the basis that it allows the Website Owner to:
(a) record the number of visitors to the Website and how they interact with the Content and how they navigate the Website and how long they spend on each part of the Website and the length of each visit. The Website Owner also collects data on the User’s IP address, the site from which the User arrived from and the site to which the User departs. This information helps the Website Owner monitor and improve Website performance and the Content.
(b) analysing the effectiveness and efficiency of the Website Owner’s marketing and promotion activities for the Website and its business, if any.
(c) respond to emails from Users.
2.4 As no personal information is collected on Users and as no monetary transaction takes place between User’s and the Website Owners and the Website, the Website Owner does not operate any AML or KYC policies. As such, no additional information will be requested from Users to comply with such requirements.
2.5 Information on Users is collected by the Website Owner, as disclosed in this Clause, is gathered on the following legal basis:
(a) User’s consent to the collection of their personal information through an affirmative action when registering their email or initiating contact with the Website Owner (note that Users are entitled to withdraw their consent at any time by giving the Website Owner a written notice);
(b) For the purpose of providing Users with information they have requested;
(c) It has a legitimate business interest for collection Users’ non-personal information on an anonymous basis – e.g. improving the performance of the Website;
(d) It is required to meet any contractual obligations to Users;
(e) To protect the financial interests of Users;
(f) It is required to be collected in the public interest, including the safety of Users and third parties; and
(g) To comply with record keeping or other legal requirements.
2.6 Except insofar as working with third parties to analyse data and develop marketing and business strategies, the Website Owner does not share, lease, sell or otherwise deal in Users’ personal data or information and the Website Owner does not disclose the identity of Users to any third party. All information, if any, that may be shared with any third-party vendors is on an anonymous basis or ppseudonymised
3. Information Sources
The Website Owner is able to collect personal data of Users in various ways, including the following methods:
3.1 Information Provided by Users to the Website Owner On the Website, this is only done through the Contact Form and the email contact form.
3.2 Information We Collect
Aside from the name and email address of Users, the Website Owner only collects non-personal information on Users on an anonymous basis. This type of information collection falls into the following categories:
(a) Information from browsers, devices and servers;
(b) Cookies and other tracking technologies;
(c) Application logs; and
(d) Analytics, including use of third-party services such as Google Analytics;
3.3 Information Secured From Third Parties None
4. Types Of Data Collected
Users’ personal information can be collected by us at various stages of their interaction with the Website. For examples cookies can start to track Users as soon as they land on the Website. The cookies will continue to track the User’s usage and how they interact with the Website.
To assist the Website Owner in providing Users an efficient and high-quality service and user experience and to enable the Website Owner to better develop its business and the services it offers, the Website Owner collects the following types of data:
(a) Personal And Financial Data
Through a combination of the Contact Form and the email registration process initiated by the User, the Website Owner collects only the information stated in Clause 2.1. No financial data is collected on Users
(b) Usage Data
- The User’s Internet Protocol address;
- Browser type and version;
- The page from which Users landed on the Website and the page of the Website on which Users landed;
- The pages of the Website Users visited and the services accessed;
- The times of entry into and exit out of the Website and the duration of the visit;
- The type of device used by Users to access the Website;
- Users’ unique mobile device ID, if any;
- Unique device identifiers and other diagnostic data;
- To ensure continuous availability of the Website, analysis of crash logs allow the Website Owner to debug in its systems.
(c) Mailing Lists
To assist us in our marketing and advertising campaigns, the Website Owner maintains a mailing list. User email addresses are collected when they make use of the Contact Form and the email Registration Form. We only add email address of Users to our marketing database with their express consent. Users are free to withdraw their consent at any time.
(d) Tracking And Cookies Data
To track and trace the use of the Website, we utilise cookies and similar tracking and tracing technologies and some of the information collected is stored in cookie files, which reside on their device(s). Cookies are sent by our server-based Website software to Users’ browser and the cookies will reside on their device(s) until they expire or are deleted. The Cookies Policy of the Website is set out in Clause 16.
(e) Data on Third Parties
The Website Owner does not seek to collect any third parties, whether related to Users or not. If the User discloses information relating to any third parties in the usage of the Website, the User shall be entirely responsible for the disclosure of such information and any consequences arising from such disclosure. The Website Owner accepts no responsibility for such disclosure of third-party information and reserves the absolute right to remove such information without any reference or notice to the User. An example of such disclosure is any statements made by a User in any posting on the Website.
5. Use of Personal Data and Location
5.1 The Website Owner uses data collected for various purposes that are justified by a legal basis and these include:
(a) Maintaining and providing the Website;
(b) To perform and/or enforce our Agreement with Users;
(c) Notifying users about changes and improvement(s);
(d) Enabling users to access interactive features;
(e) Providing access to customer and technical support;
(f) Compliance with legal obligations;
(g) Monitoring usage of the Website to maintain a stable and safe usage environment;
(h) Marketing and promotional purposes;
(i) For analytical purposes to study and analyse how Users use the Website and to measure and analyse the effectiveness of our marketing and promotion efforts.
(j) Detecting preventing and solving technical issues; and
(k) To use as is otherwise required or permitted by law or consistent with the provisions of DPA and GDPR.
In order to protect our legitimate interests and those of relevant third parties, we may undertake additional processing of personal information for the following purposes:
(i) financial reporting for analysis of financial performance and preparation of forecasts and budgets;
(ii) marketing relating activities for the purpose of identifying potential users and assessing performance of past marketing activities;
(iii) to meet any legal obligations imposed by law and/or government regulation, such as any requirement to report user details to relevant government agencies; and
(iv) to ensure internal corporate governance policies have been complied with.
5.2 Any data processing will normally take place at the premises of the Website Owner. Where the services of third parties are used, data will be transmitted to the service providers in an anonymised format. Such transfers may require transmission of the data to service providers located outside the United Kingdom and the EU. The Website Owner will use reasonable industry standards to maintain the security of the transmitted data. All services providers will be engaged on a contractual basis and will be subject to confidentiality and security provision obligations.
6. Sharing Personal Data
The Website Owner does not sell, trade, lease, rent donate or otherwise deal in the personal data of Users. If required, the Website Owner may engage third party data processors from time to time to assist in the analysis of data collected and to develop strategies to improve our Website and our marketing efforts. All data provided to third party data processors is on an anonymised basis and the third-party vendors are always appointed under a duty of confidentiality. Where the services of data processors are used, the Website Owner will use reasonable industry security standards to protect the data of Users.
7. Data Retention Period
7.1 It is the policy of the Website Owner to retain Users’ personal information for as short a period as possible. However, we will retain Users’ information on our servers for as long as required by the laws and regulations of the relevant jurisdictions and as is necessary by this P&C Policy and for the continued and efficient operation of the Website and also as required for accounting purposes and the taxation authorities. While Users’ personal information is stored on our servers, we will take all feasible measures to ensure that such personal information is safe, and we will apply a standard that is at least equivalent to that which we employ for the protection of our own confidential data.
7.2 Once any data is deleted by the Website Owner, any right of Users in respect of their personal data, anonymised or not, will be immediately rescinded and the User will have no rights to request for access or any information relating to the data other than in respect of the deletion itself.
8. User Choices Regarding Interaction With Us
With certain exceptions, the level of interaction Users have with us is within Users’ control, particularly, but not limited to the following areas:
a) Users may opt out of non-essential communications with us by using the unsubscribe option included in such messages. However, Users will continue to receive essential messages from time to time.
b) Users may disable the acceptance of cookies on their browser at any time. However, Users should be aware that the Website may not function as intended and Users will probably experience a negative experience in using the Website;
Users have the right to ask us to correct their personal information and also the right to remove their personal information (subject to Clause 8).
9. Data Transfer
9.1 Data servers of the Website Owner are located in the United Kingdom and its premises are located in the United Kingdom. The personal and other data of all Users will be located and accessed from these and other locations where the Website Owner’s remote employees and contractors may be based. Users may be located in multiple other jurisdictions and the laws and regulations regarding personal and other data may be different in such jurisdictions.
9.2 Users are hereby advised and informed that the transmission of their information or data outside the UK, EEA and USA may expose their data to a higher level of risk. The Website owner will employ reasonable industry standards to protect the information and data of Users. By accessing and continuing to use the Website, Users expressly consent to the transfer of Users’ personal and other data and information to jurisdictions outside the UK, EEA and USA and subjected to the laws and regulations of such jurisdictions.
9.3 Countries outside the UK, EEA and USA may not provide sufficient protection of Users’ personal information. To counter this, we will only send Users’ personal information to third parties outside UK, EEA and USA that agree to adhere to the terms of this P&C Policy and the DPA and GDPR standards and which are certified accordingly. Users have a right to obtain details of the mechanism under which Users’ personal information may be transferred outside of UK, EEA and USA by contacting firstname.lastname@example.org.
9.4 The Website Owner has put in place measures that are necessary to ensure that the personal and other data of all Users is securely maintained, and no data will be transferred to any third party in any jurisdiction who does not maintain and operate security protocols equivalent to those maintained and operated by the Website Owner.
Users have the right to request information relating to the transfer of their data or information outside the UK, or USA.
10. Information Users Share On Third Parties
In certain circumstances the Website may allow Users to submit information on third parties. For example, if Users use the Website to share Users’ personal information with their friends and family, Users will need to enter some personal details about themselves, including but not limited to their email address. In instances where Users provide information on third parties, the information submitted will be retained on our servers only in so far as it relates to Users’ account and such information will not, except as otherwise disclosed herein, be shared or otherwise dealt in.
11. How We Protect User Information
11.1 The security of Users’ data and information is of primary importance to the Website Owner and we shall take all reasonable measures that comply to industry standards to keep their personal and other data safe and private. However, we cannot give Users a guarantee that Users’ personal and other data will be 100% safe and secure and we make no such guarantee and/or undertaking, express or implied.
11.2 The Website and our servers are routinely scanned by high grade anti-virus and malware scanning software. All operating software is kept up to date so that all known vulnerabilities are dealt with at the earliest possible opportunity. Users’ personal information/data is stored behind secure firewalls on secure networks and is accessible only by a limited group of people in a limited set of circumstances. All such personnel are required to sign non-disclosure agreements as part of their engagement terms. All passwords used are highly sophisticated and encrypted.
11.3 All sensitive personal and other information Users supply to us is encrypted via Secure Socket Layer (SSL) technology. All financial transactions are processed by independent payment gateways and Users’ financial information is never stored in our databases or on our servers nor do we make a request to Users for such information.
12. Private Data Removal
Users have a right to request that their information be removed from the Website, our database and our servers. We will comply with such requests within thirty (30) days of receiving a written request from Users. However, please be aware that we will retain certain information relating to individual transactions Users may have conducted through the Website. We are required to retain such information for accounting, legal and taxation reasons.
13. Link To Other Websites
From time to time, we may display advertisements by third parties on the Website. To assist the third parties in assessing the performance of their advertisements, they may set cookies that allow their servers to identify Users and their activity on the Website. These cookies allow the third parties to direct more relevant advertisements to Users taking into consideration their activities on the Website and preferences.
15. Privacy of Children and Minors
Our Service is restricted to persons over the age of 18. the Website Owner does not knowingly collect data and information relating to persons under the age of 18. Any parent who is aware that their child has provided us with misleading and/or false information in order to access the Website should inform us immediately in writing by way of our contact form on the Website. Once we are aware the information on a person under the age of 18 has been collected without parental consent, we will take all appropriate actions necessary to remove such information from our records and our servers.
16. Cookies Policy
16.2 Types of Cookies
There are two categories of cookies, session or persistent. Session cookies are deleted as soon as Users close their browser or turnoff their device. Persistent cookies will remain on their device until such time that they expire or are deleted. The principal types of cookies we use are:
(a) Essential Cookies – are session cookies and are essential to the functioning of the Website. They are used to serve Users services and features available on the Website and can assist to prevent fraud by assisting in authenticating the Users.
(c) Preference Cookies – are persistent cookies that are used to remember Users’ preferences and settings to avoid Users resetting them on each visit to the Website. They are intended to enhance Users’ user experience when using the Website;
(d) Security Cookies – are persistent cookies used to maintain the security of our Website to allow all users a safe and rewarding user experience;
(e) Performance and Tracking Cookies – are persistent cookies that track information about traffic that comes to the Website and the manner in which Users utilise the Website. The information gathered by these cookies has the potential to, directly or indirectly, identify Users. These cookies can also be used, individually or in conjunction with other types of cookies, to test marketing materials, website functionality and new features.
(f) Advertising Cookies – are persistent cookies that keep track of Users’ browsing habits and patterns, and they assist our third-party vendors to work out what marketing materials and advertising are likely to be off interest to Users. They allow categories of Users to be formed according to defined criteria and targeted marketing materials and advertising to be severed to particular categories of Users. They can also be used to influence what advertisements Users will view when visiting third party websites.
The following are details of the specific cookies used on the Website:
This cookie is set by Cloudflare. The cookie is used to support Cloudflare Bot Management.
To support secure connections
This cookie is used for tracking the visitor active admin session so that the visitor does not need to re-login.
To enhance user experience and convenience of the user.
Due to the level of expertise required, Performance and Tracking and Advertising cookies, if any, would be operated on our behalf by third party vendors. The Website Owner does not use such cookies at this time.
17. Users’ Specific Data Protection Rights Under GDPR
17.1 For the purposes of GDPR, the Website Owner is defined as a Data Controller of Users’ personal information. All residents of the EEA are bestowed certain rights by GDPR in relation to their personal information/data as regards:
a) how it is collected;
b) under what circumstances it can be collected;
c) how it must be stored;
d) how it can be used; and
e) with whom and under what circumstances it can be shared.
Our legal basis of our collecting, storing, using and sharing Users’ personal information, is set out in Clause 2.
17.2 GDPR confers on EEA resident Users certain conditional rights for the protection of their personal information and/or data:
(a) to access, update or to delete certain personal information we have on Users;
(b) to rectify the correctness of any information we have on Users;
(c) right to object to our holding any information on Users;
(d) to request us to restrict the information collected on Users and how we make use of it;
(e) right to data portability for Users’ reuse elsewhere;
(f) Users have a right not to be the subject of decisions based on automatic procession or profiling; and
(g) right to withdraw the consent Users have previously given to use and request the erasure of any information we hold.
Before acting to any written request from Users in relation to the above, we may request for verification of their identity.
17.3 Where the personal information and data of the User is processes in any way for any reason whatsoever, the Website Owner shall:
i) require the User’s written request where the processing to be performed is at the User’s request;
ii) ensure that persons authorised to process the personal data are committed to confidentiality or are under an appropriate statutory obligation of confidentiality;
iii) take all measures as are required pursuant to Article 32 of GDPR for Security of Processing;
iv) respect the conditions referred to in paragraphs 2 and 4 of Article 28 of GDPR for engaging another Data Processor (referred to as a Sub- Processor);
v) on written request, make available to the User information necessary to demonstrate compliance with GDPR regulations.
17.4 Please keep in mind that we may be under legal or contractual obligations which are in conflict with Users’ GDPR rights. These conflicts may prevent us from responding to some of User requests. Users are entitled to complain to a Data Protection Authority about our conduct in the collection and use of Users’ personal information. For more information, EU residents should contact their local data protection authority in the EEA
18. CCPA Compliance
18.1 The information set out in this Clause specifically relates to residents of California and the USA which has not already been covered in other Clauses.
18.2 Since 1st January, 2020, the California Consumer Privacy Act (“CCPA”) afforded specific rights to consumers to ensure that their privacy and their personal data is protected. While the Website Owner does not fall within the ambit of the CCPA, it will voluntarily comply with its requirements on a purely voluntary basis for the benefit of our Users in the US. For the purposes of CCPA, the Website Owner would be classified as a ‘Service Provider’.
18.3 The rights conveyed by CCPA include the right to require businesses to disclose information about the collection and use of their personal information over the past 12 months. You may also ask us to delete any personal information that the Website Owner will collect from you. In the event that the Website Owner decides to sell the personal information of Users, something that will never happen, the User have the right to opt out of such sale. In the event that the User exercises any of his/her/its rights conferred by CCPA, the Website Owner is not allowed to discriminate against the User for exercising his/her/its rights.
18.4 Should the User wish to delete any of his/her/its information collected by the Website Owner, the User should send a written request to email@example.com. the Website Owner will assess the request and comply with it if the request does not wall within our exceptions to meet the User CCPA requests. These exceptions mainly relate to legal and statutory regulations which require the Website Owner to maintain certain User information. These usually relate to accounting and tax matters.
18.5 The Website Owner will not sell User information or data. Notwithstanding this, Users have a right to be excluded from any sale of information or data. User’s are free to exercise this right at any time in writing.
18.6 The Website owner will not use User information and date for any purpose which is not expressly disclosed in this P&C.
18.7 Users may require the Website Owner to disclose in portable format the following in respect of the 12-month period preceding their written request:
(a) Types and sources of information collected, purpose of collection and persons with whom sharing takes place, if any;
(b)As User information and data is collected for business purposes, User may request:
(i) where information or data is sold, the category type of each buyer; and
(ii) where information and data is disclosed, the category type of each
18.8 Users wishing to exercise their rights must do so in writing and must provide the Website Owner with verifiable information as to their identity. Users must also provide full details of their request in clear and unambiguous terms. If these terms are not met, the Website Owner shall at all times be fully entitled to decline the User’s request. User’s may only make 2 requests in any 12-month period. Any valid request, will be acknowledged within 10 days and responded to within 45 days. If more time is required, Users will be informed of the reason for the extension and the requested information will be provided within a further 45-day period.
18.9 The Website Owner reserves the right to charge User’s for any requests deemed to be unjustified or excessive.
18.10 The Website Owner undertakes not to discriminate against Users in any way should they elect to exercise their rights under CCPA.
19. Residents of other Jurisdictions
Residents of countries and jurisdictions not expressly mentioned in this P&C are also covered by all the provisions set out herein. The Website Owner is of the view that the provisions of this P&C are sufficient to meet the requirements of all jurisdictions in which this Website will be accessed and used within the context of the business model used for the Website, the information and data that is collected and the purposes for which it is used. If any User is not satisfied that the P&C meets the requirements of his/her jurisdiction, they should make a written submission to the Website Owner giving full details of their views. Please be aware that the Website Owner will only be able to address the concerns of Users if detailed information on their concerns is submitted. All submissions should be sent to firstname.lastname@example.org.
20. Google Analytics
20.2 Users also have the option of using an add-on provided by Google that allows Users to control what information is collected on them. This add-on only functions to restrict data sent to Google and does not restrict any data sent to the Website Owner or any of its third-party contractors. Users also have the option of opting out of Google Analytics through this URL – https://tools.google.com/dlpage/gaoptout.
20.3 In relation to any data moved out of the EEA, Google is part of the Privacy Shield programme on a self-certified basis. Further information on how Google uses the personal information of users can be found at https://www.google.com/intl/en/policies/privacy/.
21. Changes To P&C Policy
The Website Owner at all times reserves the right to change any and all aspects of this P&C Policy at any time without giving advance notice of such changes to Users and without giving reasons for such changes. If the Website Owner does give any explanation for changes in the P&C Policy, it is done so only as a courtesy and not as a requirement. Any changes to the P&C Policy shall become effective immediately the new P&C Policy is posted on the Website and a notice of such changes is posted on the Website. All Users are advised to review our P&C Policy from time to time to keep themselves updated on any changes.
22. VPN Users
Users who use a VPN (Virtual Private Network) to access and use the Website for any reason, including but not limited to, circumventing the laws and regulations of their jurisdiction do so entirely at their own risk. The Website Owner shall not be responsible for and shall not accept liability for any losses suffered or penalties incurred by Users as a result of using a VPN.
23. Data Protection Personnel
If Users have any queries regarding this P&C Policy or their personal data and information, Users may contact our Data Protection personnel via email to email@example.com.
24. Contact Us
You may contact the Website Owner for any purposes at firstname.lastname@example.org.
25. Effective Date
This Privacy and Cookies Policy is effective from the 31st July, 2022 and shall remain in effect until such time it is superseded by an update or terminated by the Website Owner.