FX Blue Privacy Notice

FX Blue is committed to protecting and respecting your privacy and seeks to comply with all applicable laws. This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL DATA

5. LAWFUL BASES ON WHICH WE WILL USE YOUR PERSONAL DATA

6. DISCLOSURES OF YOUR PERSONAL DATA

7. INTERNATIONAL TRANSFERS

8. DATA SECURITY

9. DATA RETENTION

10. YOUR LEGAL RIGHTS

11. STATUS OF THIS PRIVACY NOTICE AND CHANGES

1. Important information and who we are

Purpose of this Privacy Notice

Personal data is data that identifies you or can be used to identify you directly or indirectly, such as your name, address, email address and telephone number, information on you usage of our products and services and any information about you that is directly linked to such personal data (“Personal Data”).

The purpose of this Privacy Notice is to outline how FX Blue LLP (“FX Blue” or “we”) collects and processes your Personal Data when you visit the website at www.fxblue.com (“Website”) or use their services and products. This includes any data you provide when you register with FX Blue to use free services, download software, purchase a product or service, or take part in a competition. This Privacy Notice also explains your privacy rights and how the law protects you.

FX Blue acts as the controller of your Personal Data. The term you or your or user or users refers to the users or viewers of this Website or users of FX Blue products and services.

This Website and the products and services we provide through it are directed to adults. The Website is not intended for children under the age of 18.

Contact details

Our full details are:

• Full name of legal entity: FX Blue LLP
• Email address: dataofficer@fxblue.com
• Postal address: 124 City Road, London, England, EC1V 2NX
• Telephone number: +420 605 589 104

We are not required to appoint, and have not appointed, a Data Protection Officer. The data protection contact for any queries about this Privacy Notice or our processing of your Personal Data is the email address above.

2. The data we collect about you

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.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Usage Data includes information about how you use our Website, products and services, including overview of all purchases and any complaints and feedback related to them.
• Financial and Transaction Data includes bank account and payment card details, payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

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.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that 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 goods or services). In this case, we may have to prevent access to or cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your Personal Data collected?

We use different methods to collect data from and about you including:

• when you register and create an account on our Website
• when you give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
  • apply for our products or services, including downloading our software and using the services on the Website
  • subscribe to our service or publications
  • request marketing to be sent to you
  • enter a competition, promotion or survey
  • give us some feedback
• when you or your organisation provides or offers to provide services to us
• through cookies and automated technologies or interactions (see our Cookie Policy for full details of the cookies we use and how to manage them). As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. FX Blue uses cookies to automatically access your previously stored account information, to deliver more personalised services and to estimate FX Blue's audience size and usage patterns which helps FX Blue to optimise the Website, advertisement placement, and marketing focus. FX Blue may place a pixel on pages on the Website, or those of FX Blue's advertisers and partners. This enables FX Blue to record in its server logs that a specific user id has visited a particular page. Advertising networks that serve ads onto the FX Blue Website may also use cookies. Please note that FX Blue neither controls nor has access to those cookies and these advertisers' uses of cookies are subject to their own privacy policies and not FX Blue's.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, and from other publicly available registers and databases in the UK and other jurisdictions where we operate.
• If you are a job applicant when you apply for a job and provide Personal Data as part of the pre-application and application process.

4. Purposes for which we may use your Personal Data

Most commonly, we will use your Personal Data in the following circumstances (Permitted Purposes):

• To provide services that you or your organisation has requested or to optimise your experience when using our Website.
• Managing and administering your or your organisation's relationship with us including processing payments, accounting, auditing, billing and collection and support services; and analysing and improving our services and communications to you.
• If any of our services or products contain advertising from third parties using your Personal Data to help us deliver more relevant content and advertisements to you. In these cases we do not disclose your Personal Data to any advertisers but we may disclose to them anonymised information about you that does not directly or indirectly reveal your identity.
• Where we need to perform a contract we are about to enter into or have entered into with you. Compliance with our legal obligations including record-keeping, compliance screening or recording obligations (e.g. for anti money-laundering, export laws, trade sanction and embargo laws, financial and credit checking, fraud and crime prevention and detection purposes); and complying with legal and regulatory requests from national and international regulatory bodies.
• Protecting the security of our services, premises, IT and communications systems, Websites and other systems, including detecting and preventing fraud, unauthorised access, abuse of our services, and other security incidents; verifying your identity when you create or access your account.
• Monitoring and determining compliance with our policies and standards.
• For insurance purposes.
• Compliance with court orders and establishing, exercising and defending legal claims.
• If you are a job applicant, for the purpose of processing your job application that you submit to us, directly or via an agent or recruiter (speculatively or in response to any advertisement).
• For any other purpose connected with any of the above purposes, and for any other purpose for which you have provided your Personal Data.

Marketing

Marketing of our own services. Where you are an existing customer, we may send you marketing communications about our own similar products and services (such as news about new developments) by email, unless you have told us you do not want to receive them. You can opt out at any time by following the unsubscribe link in any marketing communication we send you.

Third-party marketing. We will get your consent before we share your Personal Data with any other person for marketing purposes. For example, some of our services such as free software may be sponsored by our trusted third-party partners and we may share your Personal Data with them, but only where we have your prior consent to do so. You can withdraw that consent at any time.

Job Applicant

If you are a job applicant, we will process the Personal Data you provide as part of processing your job application that you submit to us for the purposes of evaluating your application, communicating with you about the role, conducting any pre-employment checks permitted by law, and complying with our legal and regulatory obligations as a prospective employer. We will retain your application data only for as long as necessary for these purposes.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We do not make decisions about you based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Lawful bases on which we will use your Personal Data

In most cases the lawful basis for which we hold and process your Personal Data is:

• on the basis of our legitimate interests as a business that provides you with services or products or on the basis of the legitimate interests of a third-party recipient of your Personal Data, where such interests are not overridden by your interests or fundamental rights and freedoms which require protection of Personal Data, or
• if processing is necessary for us to perform any contract with you (for example to provide you with a service that you have contracted to receive)

In some cases the lawful basis for which we hold and process your Personal Data will be:

• if you have given your consent for the processing of your Personal Data, processing that Personal Data for the purpose for which you gave your consent which you can withdraw at any time – see below.
• if processing is necessary to comply with our legal obligations (e.g. to keep records for tax purposes).

The table below sets out the lawful basis we rely on for each of our main processing activities:

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your Personal Data

We may have to share your Personal Data with other parties in certain circumstances.

We share your Personal Data with IT companies and other third-party service providers that provide services or support for our Website and other business systems, with our various professional advisers where it is reasonably necessary to obtain advice or services relating to the operation of our business. In these circumstances FX Blue will retain control over and will remain responsible for your Personal Data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your Personal Data.

In order to facilitate payment processing and related actions, we may share your Personal Data with payment service providers and financial institutions.

We may share your Personal Data with third parties who collect feedback on our services from you and from clients for the purpose of measuring, improving and promoting our services and products.

Some of our services such as free software downloads may be sponsored by our trusted third-party partners and we may share your Personal Data with them but only where we have your prior consent to do so.

We may share your Personal Data with HM Revenue & Customs, regulators and other authorities as well as the police and similar bodies, hospitals and doctors, when we are required to do so by law or where this is to prevent a crime, or necessary in the event of a medical emergency.

We may share your Personal Data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal claim or for the purposes of a confidential alternative dispute resolution process.

We may provide your Personal Data to other organisations that provide credit check and international sanctions services or for other fraud and crime prevention purposes including financial institutions, credit reference agencies and regulatory bodies.

We may share your Personal Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy statement.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

7. International transfers

We may transfer your Personal Data to recipients outside the United Kingdom. Where we do so, we will only transfer your Personal Data to a country, territory or international organisation outside the UK if

• there is an adequacy regulation recognising that the destination provides an adequate level of protection for personal data (such as the European Economic Area, and other jurisdictions);
• the transfer is covered by an appropriate safeguard recognised under the UK GDPR, such as the International Data Transfer Agreement (IDTA), or Binding Corporate Rules; or
• other specific derogation set out in the UK GDPR applies.

We may store your Personal Data on servers operated by third-party cloud-based service providers such as Amazon Web Services and Google Cloud and others, some of which are located outside the United Kingdom, so our processing of your Personal Data may involve a transfer of Personal Data outside the UK.

Please contact us if you want further information on the specific safeguard or mechanism, we rely on for a particular transfer of your Personal Data out of the UK.

8. Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my Personal Data for?

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

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 requirements.

Our retention periods we typically apply are:

• Account and profile data— for as long as your account is active, plus 12 months after closure to handle any post-termination queries or disputes.
• Transaction and financial records— 6 years from the date of the transaction to meet UK accounting and tax record-keeping requirements.
• Marketing preferences and consent records— for as long as you remain subscribed, and a further 24 months after you unsubscribe to evidence that the unsubscribe was actioned.
• Website usage data, cookies and analytics— typically 13 months from collection unless aggregated or anonymised.
• Job applicant data (unsuccessful applicants)— 12 months from the close of the recruitment process unless you ask us to keep your details for future opportunities.
• Correspondence and support enquiries— 3 years from the last interaction, to address any follow-up queries, disputes or regulatory matters arising from the interaction.
• Records held for legal, regulatory or dispute purposes— for as long as required by the applicable obligation or statute of limitation period.

In some circumstances you can ask us to delete your data: see request erasure below for further information.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. 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. 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 when processing your Personal Data you may object to such processing. You also have the right to object where we are processing your Personal Data for direct marketing purposes. However, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms and, in such case, we will not comply with the objection.
• Request restriction of processingof 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.
• Make a data protection complaint directly to us, using the contact details in section 1 or the complaints process described below.
• Lodge a complaintwith the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). You can exercise this right after your complaint has not been resolved to your satisfaction by us.

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

Responding to your rights requests. We try to respond to all legitimate requests to exercise your rights (such as access, correction or erasure) within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data protection complaints process. If you have a complaint about how we handle your Personal Data, please contact us at dataofficer@fxblue.com. We will acknowledge your complaint within 30 days of receipt and will investigate and respond to it without undue delay. If you are not satisfied with our response, you remain entitled to complain to the Information Commissioner's Office (www.ico.org.uk).

11. Status of this Privacy Notice and Changes

Privacy Notice version 2026. It is a non-contractual document and we reserve the right to amend it from time to time to reflect changes in law, changes in our business practices and changes in our Personal Data processing activities.

Where changes are material we will notify you by email or by a prominent notice on the Website before the changes take effect. The current version will always appear on our website at www.fxblue.com, together with the date on which it was last updated.

Contact

• Contact Us Form
• support@fxblue.com