OANDA CORPORATION
Rate Subscriptions
Privacy Policy
A.
Policy Statement
OANDA
Corporation respects customer privacy and is committed to protecting it.
Customers can visit most pages on the OANDA website and mobile
applications—and use all of the currency tools located on our
site—without identifying themselves or providing any personal or
financial information. However, if a customer wishes to open a rate
Subscription Services account, customers are required to provide OANDA with
certain non-public client information (referred to as “Client Information”).
The purpose of OANDA’s Privacy Policy is to explain OANDA’s privacy policy and
practices and how customer Client Information is collected, used, disclosed and
maintained.
B.
Categories of Client Information OANDA Collects
OANDA
collects Client Information about our customers from the following sources:
Account
Application Forms and other documents and data submitted by customers, such as
customer or business name and business address;
Customer
Transactions with OANDA such as subscription payments that require customers to
provide payment information;
Communications
with OANDA customer service representatives; and
“Cookies” described in section J below.
OANDA
will not collect more Personal Information than is required to open and operate
customers’ accounts, and to comply with regulatory obligations.
C.
How OANDA Uses Client Information
OANDA
may use Personal Information as necessary to:
effect, administer or enforce transactions requested
or authorized by the customer, and
maintain or service the customer’s account with OANDA.
Client
Information collected online may be combined with other information customers
provide to OANDA in hard copy or through the OANDA help desk. OANDA will not
use or disclose or sell, rent or lease any Client Information about its customers
or former customers to any third parties except as stated in this Policy.
Client Information may be transferred across national borders for the purposes
of data consolidation, storage and customer data management.
D.
Disclosure of Customer Client Information
OANDA
may disclose Client Information of current and former customers to affiliated
and non-affiliated third party entities in the following cases:
to OANDA’s business partners that perform services on OANDA’s
behalf under written agreements which restrict use of Client Information to the
limited purposes for which it is provided to them and to refrain from further
use or disclosure except as permitted by law;
to OANDA affiliates, who are permitted to disclose and use the
information only to the extent that OANDA may disclose and use the information
under this Policy;
in the ordinary course of business to OANDA’s attorneys,
accountants and auditors;
to persons holding a legal or beneficial interest relating to the
customer’s account;
to persons acting in a fiduciary, representative, or attorney
capacity in relation to an account;
to protect against actual or potential fraud, unauthorized
transactions, claims or other liability;
to government, regulatory or law enforcement agencies to the
extent permitted or required by law, or to comply with applicable legal
requirements; or
to comply with civil, criminal or regulatory investigations,
or judicial process, subpoena, summons or warrant by federal, state or local authorities.
E.
Permission to Disclose Client Information
Except
as stated in this Privacy Policy, OANDA will not share Client Information about
any present or former customer with any non-affiliated third party without the
customer’s prior written consent or providing the customer with a clear notice,
an opportunity to “opt out” of that disclosure, and information on how to opt
out.
F.
Procedures to Safeguard Client Information
OANDA
has implemented procedures to safeguard customer Client Information. OANDA
restricts access to Client Information to those OANDA employees who need to
know that information in order to provide our products or services to them.
OANDA maintains physical, electronic and procedural safeguards to safeguard
Client Information. OANDA protects customer account information by keeping it
on the secure portion of its website, using firewalls and other security
technology to protect its network and systems from external attacks, and by
requiring customers to enter a unique user ID and password to access the Self
Service Portal. OANDA conducts periodic internal audits of its business
practices and procedures, examining its confidentiality standards and
information access, in order to best protect our customers’ Client Information.
G.
Retention of Client Information
OANDA
only keeps Client Information on file for as long as it is required to provide
customers with products and services, and to meet legal requirements. When
OANDA no longer needs the Client Information, it is either destroyed or made
anonymous.
H.
Accuracy
OANDA
attempts to ensure the accuracy of the Client Information collected. OANDA
records the dates when Client Information was obtained from customers and will
periodically ask customers to review the Client Information OANDA has on file
and to update any Client Information that may have changed.
I.
Customer Recourse
Any
concerns a customer may have regarding OANDA’s privacy practices or specific
complaints about how customer Client Information has been collected, used or
disclosed should be forwarded in writing to OANDA’s Privacy Officer. OANDA will
thoroughly investigate the complaint and will take whatever actions are
warranted and notify the customer once this has been done.
J.
Cookies
OANDA
uses tracking mechanisms, such as cookies, to: (i)
facilitate customer use of our website and mobile applications, (ii) enable
customization of our online services and website features, (iii) avoid customer
re-entry of data, (iv) store customer preferences for
certain kinds of information, and (v) gather data about usage of our website
and mobile applications for research and promotions. Cookies stored on
customers’ web browsers by OANDA cannot be read by, and are not shared with,
any third parties. Customers can configure their browser preferences not to
accept these cookies. OANDA uses third party tracking mechanisms to facilitate
website and mobile applications tracking and may share the information
collected with third parties acting as our service providers, who are required
to maintain the confidentiality of the information. Customers can configure
their browsers preferences not to accept third party
cookies, however this may result in reduced functionality.
Some
third-party vendors that provide ads on OANDA web pages may use cookies to
collect details on customer website visits and other data (but not names,
addresses, email addresses, or telephone numbers) in order to provide ads about
goods and services of particular interest to individual customers. For more
information on this practice or to opt out, customers can visit the Network
Advertising Initiative site. Opt-outs are also available for Google Analytics
and MobileAppTracking.
K.
Links to non-OANDA websites
The
OANDA website may provide links to third-party websites for customer
convenience and information. If customers decide to access those links, they
will leave the OANDA website. OANDA does not control those third-party sites or
their privacy practices, which may differ from OANDA's. OANDA does not endorse
or make any representations about third-party websites. Any Client Information
customers choose to give to unrelated third parties is not covered by OANDA’s
privacy policy. Customers should review the privacy policy of any third-party
website before submitting Client Information. Some third-party companies may
choose to share their Client data with OANDA. That sharing is governed by the
disclosing company's privacy policy.
L.
Sharing Information with Our Affiliates
OANDA
may share Client Information described above with OANDA’s affiliates for
business purposes, such as, but not limited to, servicing customer accounts and
informing customers about new products and services. OANDA’s affiliates may
include companies controlled or owned by us as well as companies that have an
ownership interest in OANDA. The information we share with affiliates may
include any of the information described above, such as your name, address and
account information. OANDA’s affiliates maintain the privacy of your
information to the same extent OANDA does in accordance with this Policy.
M.
Notification of Privacy Policy and Policy Changes
OANDA
provides an initial notice of its Privacy Policy to customers at the time it
establishes a customer relationship, and at least annually thereafter, and the
Privacy Policy is posted on its website. Updates will be posted on the OANDA
website, so our customers will always know what information we
collect, how we use it, and what choices they have.
N.
Contact Us
OANDA
values its customers’ opinions. If customers have comments or questions about
OANDA’s Privacy Policy, they are invited to contact OANDA at:
Email:
privacyoffice@oanda.com
Regular
Mail: OANDA Privacy Mailbox, 46th Floor, 140 Broadway, New York, NY 10005,
U.S.A.