ProSpreads - The Professional's Choice

Data Protection Act

ProSpreads Ltd may process information relating to you (including personal data as defined under the Data Protection Act 2004), including holding such information in a manual format or electronic database, in order to satisfy any contractual, regulatory or statutory requirements we may have. Unless we receive specific written instructions to the contrary, by providing this information you agree that we may process this information in order to fulfill such obligations.

Gibraltar Data Protection Act 2004

The Government of Gibraltar passed a Data Protection Act in 2004. ProSpreads Ltd is bound to comply with the principles of good practice in the processing of personal data. Details of Data Protection registration may be found on their website; www.gra.gi

Privacy Policy

Introduction:
Protecting the security and privacy of your (customer, shareholders and others) personal information is important to ProSpreads Ltd and to the way it conducts its business in compliance with laws on privacy, data protection and data security. ProSpreads Ltd hopes the policy outlined below will help you understand what information ProSpreads Ltd may collect, how it uses and safeguards that information and with whom it may share it.

At ProSpreads Ltd, we are committed to maintaining the highest standards of integrity in our business. Our business is to meet our customers' needs for a range of financial services. To do this effectively, we need to collect certain personal information about our potential clients. We take this activity seriously and seek to provide fair, secure and appropriate methods for the handling of Personal Information. All such activities are intended to be consistent with both generally accepted privacy ethics and standard business practices. Your Personal Information may be shared with the parent company LCG and a limited number of trusted partners and/or affiliates of ProSpreads Ltd where such use is restricted to the management of your account and will not breach any elements of the Data Protection Act 2004.

If you have any questions or comments about ProSpreads Ltd’s Privacy Policy, you can contact our Customer Support Team: support@prospreads.com or +44 (0)203 370 6222

Personally Identifiable Information

The type of personal information we may collect can include (but is not limited to) name, address, date of birth, contact details, income, assets and liabilities, account balances, trading statements, tax and financial statements and employment details.

We obtain most of the information directly from our customers through application or other forms, and from maintaining records of information provided in the course of ongoing customer service. We may also obtain information from other sources.

We may ask for other information voluntarily from time to time (for example, through market research, surveys or special offers) to enable us to improve our service or consider the wider needs of our customers or potential customers. If you choose not to provide the information we need to fulfill your request for a specific product or service, we may not be able to provide you with the requested product or service.

While we may send you marketing material from time to time that we think will be useful to you, we are conscious of the need to respect your privacy. You may opt out of receiving marketing emails at any time by selecting the 'unsubscribe' link at the top of the emails or by emailing support@prospreads.com with your request.

If you do not want your personal information collected, please do not submit it.

Unless you are informed otherwise, the personal information we hold is used for establishing and managing your account, reviewing your ongoing needs, enhancing customer service and products and giving you ongoing information or opportunities that we believe may be relevant to you.

Depending on the product or service concerned and particular restrictions on sensitive information, this means that personal information may be disclosed to:

• other companies within our group who provide financial and other services;
• service providers and specialist advisers to us who have been contracted to provide us with administrative, financial, insurance, research or other services;
• introducing brokers with whom we have a mutual relationship (any of whom may be within or outside the European Economic Area);
• credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
• credit reporting or reference agencies; and
• anyone authorised by an individual, as specified by that individual or the contract.

Generally, we require that organisations outside our group of companies who handle or obtain personal information as service providers acknowledge the confidentiality of this information, undertake to respect any individual's right to privacy and comply with the Data Protection Principles and this policy.

If you choose not to have your personal information used to support its customer relationship programmes (especially direct-marketing or market-research), ProSpreads Ltd will respect your choice. ProSpreads Ltd do not now (and do not intend to in the future) sell, rent or otherwise market your personal information to third parties.

Children

No personal information should be submitted to ProSpreads Ltd’s websites by children without the consent of their parent or guardian. ProSpreads Ltd encourages all parents or guardians to instruct their children in the safe and responsible use of their personal information while using the Internet. ProSpreads Ltd will not knowingly collect or use any personal information collected from children for any purpose whatsoever, including disclosure to third parties.

Non-Personal Information Collected Automatically

When you access the website, ProSpreads Ltd may automatically (i.e. not by registration) collect information that is not personally identifiable (e.g. type of Internet browser and computer operating system used; domain name of the website from which you came; number of visits, average time spent, pages viewed). ProSpreads Ltd may use this information and share it within the ProSpreads Ltd group to measure the use of its website and improve its content.

Privacy Statement Changes

ProSpreads Ltd may change this privacy statement at any time. You are advised to read this statement each and every time you access the site so that you are satisfied with the privacy conditions under which you provide ProSpreads Ltd with your personal information.

Retention of records

We will keep Personal Information only as long as it is necessary, however, this may be for a significant period of time. When the Personal Information is no longer required, it will be destroyed either by shredding or other approved destruction methods to prevent unauthorised parties from gaining access to the information during and after the process. We will safeguard information in our custody.

Management of personal information

We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal.

Our Compliance Department is responsible for ensuring that our management of personal information is in accordance with this statement and the Privacy Act.

Security

ProSpreads Ltd takes precautions to ensure the security of your personal information. ProSpreads Ltd carefully protects your personal information from loss, destruction, falsification, manipulation, and unauthorised access or unauthorised disclosure and has developed and will maintain security procedures to safeguard Personal Information against loss, theft, copying, and unauthorised disclosure, use or modification. Access to Personal Information is restricted to employees and authorised service providers who need it to perform their work. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

How do we keep personal information accurate and up-to-date?

We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. We can generally update your customer information over the telephone.

You have the right to check what personal information about you is held by us. Under the Data Protection Act, you have the right to obtain a copy of any personal information which we hold about you and to advise us of any perceived inaccuracy.

The Act does set out some exceptions. To make a request, please write to us, verifying your identity and specifying what information you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. We will acknowledge your request and respond to it within 21 days of receipt of your application and any applicable fee.

What if you have a complaint?

If you consider that any action of ours breaches this Privacy Policy Statement or the Data Protection Principles or otherwise doesn't respect your privacy, you can make a complaint. This will be acted upon promptly. To make a complaint, please email:  compliance@prospreads.com

If you are not satisfied with our response to your complaint, you can telephone the Gibraltar Regulatory Authority tel:(+350) 20074636

What is a cookie and how do we use cookies?

Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on the website, when you return to the website, where you came from, and to ensure your information is secure. The purpose of this information is to provide you with a more relevant and effective experience on this website, including presenting web pages according to your needs or preferences.

We may also use independent external service providers to track the traffic and usage on the website. Cookies are frequently used on many websites on the internet and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of this site if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website. We therefore recommend you enable cookie acceptance to benefit from all the services on the website.

How we use cookies on our site:

LCG uses cookies to improve your experience on our websites. We do not link the information we store in cookies to any personally identifiable information you may submit whilst on our site. If you choose to opt out of cookies you may still use our site, but your ability to use some areas will be limited. In certain circumstances, there may be occasions where our content management system generates a wholly anonymous and non-intrusive cookie to your system that has not been outlined below that is strictly necessary for this website to function correctly.

Strictly necessary	Name	Purpose	Type
User session ID	PHPSESSID ASP.NET_SessionId	Allows our web servers to respond to your actions on our website.	Session
Secure platform access	WIAuthID WINGDevice WINGSession WIUser	Ensures secure access to our platform hosted on Citrix.

Performance cookies	Name	Purpose	Type
Google Analytics	UTM_a UTM_b UTM_c UTM_v UTM_z	Used to understand how our website is being used in order to improve user experience.	Session & Persistent (up to 2 years)
Adform	TPC uid C cid GCM ADFstat	Creates a randomly generated user ID to identify repeat visits by users and help us to understand users’ journeys on our site.	Session & Persistent (up to 60 days)
ClickDensity / Intellitracker	Vidi ltc	Gathers typical web performance data such as information on referrer, content and page interactions.	Persistent (5 years)

Targeting or advertising cookies	Name	Purpose	Type
Affiliates	Agentid	Allows us to credit affiliate websites for driving traffic to our website.	Persistent (90 days)

We would strongly recommend that you allow cookies on our website to ensure you have the best possible experience of our service. Turning off cookies may result in reduced performance of our website and trading platform, however if you would still like to opt out of cookies, you can do this through your website browser. Our customer support team would be happy to assist you through this process.