Prior to offering our services to you, we require you to read this Privacy & Security Policy.
Version: 2018 June
Privacy & Security Policy, 2018PRIVACY AND SECURITY POLICY
1. ABOUT FEDTTM BILLIONAIRES
2. FedTtm Billionaires
2.1 is a registered trading name of IX Capital Group Limited, formerly FedTtm Billionaires Limited, which is
authorized and regulated by the Securities Commission. FEDTTM BILLIONAIRES is authorized by SCB to
deal, arrange and manage Securities. We help traders and Introducing Brokers achieve their business
goals and personal ambitions by offering an extensive portfolio. Our business is built on integrity and
trust, offering an industry leading combination of dynamic products, competitive trading parameters and
premium, one-on-one service. It is FEDTTM BILLIONAIRES’s mission to enable the personal ambitions
and business goals of FOREX traders and IBs, through underpinning dynamic
productswithcompetitivetradingparametersandapremiumcustomer experience.
2.2 If you have any questions about this policy or how we collect and use personalinformation about you please
contact us usingthecontactdetails providedbelow. We alsohave adedicated Data Compliance Officer, who
isresponsible for data compliance issues.
Postal Address:
FedTtm Billionaires
109 Church Street, Sandyport Marina Village Nassau, NewProvidence
The Bahamas SP- 62756
Phone number: +44 203 713 4490
Email: compliance@FedTtm Billionaires.bs
3. FEDTTM BILLIONAIRES’S COMMITMENT
3.1 FEDTTM BILLIONAIRESiscommitted to protect the privacy ofyour personal and financial information
obtained to enable us to provide you with a secure website for you transactions. This policy confirms
details how FEDTTM BILLIONAIRES manages the information provided to us by you or a third party in
connection with our provision of services to you or which we collect from your use of our services via
out website(s) and app(s). FEDTTM BILLIONAIRES will use your personal information in accordance
with this Privacy and Security Policy and otherwise in accordance with The Bahamas Data
Protection(Privacy ofPersonal Information)
Actand the United Kingdom dataprotection
legislation(s).
3.2 Dataprotectionregulationsrequirethatthe personalinformationweholdabout you must be:
Used lawfully, fairly and in a transparent way.
Collectedonly forvalid purposesthatwehaveclearly explained to you andnotusedin
anyway thatis incompatible with thosepurposes.
Relevant to the purposes we have told you about and limited only to thosepurposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
4. REASONS FORCOLLECTINGPERSONAL INFORMATION
4.1 FEDTTM BILLIONAIRES collects certain personal information in order that it may meet the needs of its
customers. By collecting certain personal information, FEDTTM BILLIONAIRES is able to monitor and
improve the services which it offers to its existing and potential customers.
4.2 FEDTTM BILLIONAIRES will use thisinformation forthe following purposes:
verifying your identity;
assessing the suitability of the products and services we provide;
establishing and maintaining your account;
providing our services to you;
improving our services;
regulatory requirements; and
marketing.
5. PERSONAL INFORMATION COLLECTED FROM YOU
5.1 FEDTTM BILLIONAIRESwillcollectandholdinformationaboutyouwhenyoucomplete anonlineapplication
orother type of form or accessand trade on youraccountthrough thiswebsite or anotherservice we
provide toyou.Thekind ofpersonalinformationyougive usmayinclude(butisnotlimitedto)name,address,
date of birth, passport number, tax identification number, email address telephone number,
employment and income information,credit/debitcardinformation,transactionhistoryandfinancial
statements.
5.2 FEDTTM BILLIONAIRES may derive information from your use of this website or another service we
provide to you and may store this information with your personal profile. This information may include
site areas visited, pages viewed, frequency and duration of visits, types of transactions conducted,
documents downloaded and otherwebsiteswhichmay have referredyou ortowhich you link.
5.3 By opening an account with FEDTTM BILLIONAIRES and by placing Orders and entering into transactions,
you acknowledge that you will be providing personal information (possibly including sensitive data) within
the meaningof The BahamasDataProtection(Privacyof PersonalInformation)Actandthe United Kingdom
Data Protection Act 1998 orthe General Data Protection Regulation“GDPR” or any other applicable laws and
regulations to us, and you consent to the processing of that information by FEDTTM BILLIONAIRES for
the purposes of performing its obligations under this Agreement and administering the relationship
between you and FEDTTM BILLIONAIRES, including the disclosure of the information to Affiliates both
within and outside The Bahamas, EuropeanUnion and/or European Economic Area.
5.4 FEDTTM BILLIONAIRESneedscertaininformation tocarry
outanagreementwithyouandyoumustprovidethisin order to enterinto an agreementwith FEDTTM
BILLIONAIRES to provide you with products and service. If you do not, we may not be able to offer you any
products or services. Mandatory information fields are generally set out in theapplication.
5.5 Other correspondence or interaction (for example by email, telephone, post, SMS or via our website)
between you and FEDTTM BILLIONAIRES, will include personal information (such as names and contact
details) in that correspondence. This may include enquiries, reviews, follow-up comments or
complaints lodged by or against you and disputes with you or your organization.
5.6 FEDTTM BILLIONAIRES may also collect details of phone numbers used to call our company and the
date, time and
durationofanycalls.PleasenotethatifwerecordyourcallstoorfromFEDTTM
BILLIONAIRES,wewillinformyou of this.
6. USE OF PERSONALINFORMATION
6.1 FEDTTM BILLIONAIRESmaykeepandusesuchinformation to complywithanylegalrequirements or if
it is necessaryfor our legitimate interestorfor any one ormore ofthe following purposes:
a. Toprovidetheservicestoyouthatyou haverequestedincludingprocessing transactions.
b. To confirm youridentity.
c. Tomaintain your personal profile.
d. To manage youraccount.
e. Tocontactyou whennecessary orappropriateinrelationtotheservicesbeing providedtoyou.
f. Tokeepyouupdatedwhilstyouareacustomer inrelation tomatters suchascontractsyouhavetraded
and activities ofFEDTTM BILLIONAIRES.
g. Tomanage and administerthe products andservices provided to you.
h. Toprovideyouwithinformation regarding theproducts andservices offeredbyFEDTTM
BILLIONAIRES.
i. Todevelopanunderstandingoftheproductsandservicesthatyoumaybeinterestedinobtainingfrom
FEDTTM BILLIONAIRES.
j. Toprovideyouwithinformation oropportunitiesthatwebelievemaybe relevanttoyou.
k. Totailorthe website orotherservicewe provide toyoutoyourneeds andinterests.
l. To create anonymised statistical data.
6.2 YouconsenttoFEDTTM BILLIONAIRESusing yourpersonal informationforthe above-stated purposes.
6.3 Where we use your personal information for marketing purposes to inform you about FEDTTM
BILLIONAIRES’s products and services that might be of interest to you, you always have the right to ‘opt
out’ of receiving such a communication.
6.4 Youcanexercisetherightatanytime by contacting us usingthedetailsprovided atthestartof thispolicy. Ifwe
sendyouanymarketingemails,wewillalwaysprovideanunsubscribeoptiontoallowyoutooptout ofany
further marketing emails. If you “opt-out” of our marketing materials you will be added to our
‘suppression list’to ensure we do not accidentally send you further marketing. Where you unsubscribe from
anypostalmarketing, you may initially stillreceive some contentwhich hasalreadybeen printed or sent, but
we will remove you from any future campaigns. We may still need to contact your administrative for
operationalpurposes, butwewillmakesurethatthosecommunications do not includedirectmarketing.
6.5 If youareanexisting customer orare actingasabusiness we useyour contactdetailsasnecessary forour
legitimateinterestsinmarketing toyouandmaintaining a listofpotentialcustomers.
6.6 Ifyou arenotanexistingcustomer, andarenotactingasabusiness, wewillonlycontactyouformarketing
purposeswithyourconsent(whetherwehavecollectedyourdetailsdirectlyfromyou, orthroughathird
party).
6.7 FEDTTM BILLIONAIRES will only use your personal information for the purposes forwhich it collected it
assetout in this policy, unless FEDTTM BILLIONAIRES reasonably considers a need to use it for another
reason and that reason is compatible with the original purpose. If FEDTTM BILLIONAIRES needs to use
your personal information for an unrelated purpose, FEDTTM BILLIONAIRESwillnotifyyou
andwillexplain the legalbasis whichallows to do so.
7. DISCLOSURE ANDSHARINGOFPERSONAL INFORMATION
7.1 FEDTTM BILLIONAIRES does not sell, license or otherwise disclose your personal information to third
partiesfor marketing purposes.Wedousethirdpartyserviceproviderstosendoutourmarketing,butwe
onlyallow them to use
thatinformationonourinstructionsandwheretheyhaveagreedtotreattheinformationconfidentiallyand to
keep itsecure. FEDTTM BILLIONAIRES may be required to provide your personal information to the SCB
and other regulatory and government bodies from time to time in The Bahamas, the United Kingdom
and other countries. FEDTTM BILLIONAIRES may also disclose your personal information to:
a. Financial institutions and other similar organizations that it deals with in the course of its corporate
activities, or those that are nominated by you.
b. Externalservice providers andprofessionaladvisers(whichmay be locatedoverseas)that provide
services to FEDTTM BILLIONAIRES.
c. Any organization at your request or any persons acting on your behalf, including your financial adviser,
broker, solicitor oraccountant.
d. Any third parties where thisis necessary to process atransaction or provide serviceswhich youhave
requested; oranyauthoritytowhomFEDTTM
BILLIONAIRESisrequiredtodisclosesuchinformationbylaw.
7.2 Inthe eventthat FEDTTM BILLIONAIRES is subject to negotiationsforthesaleofitsbusiness(whole
orpartyof), or sold to a thirdparty or undergo a re-organization, youagreethatany of
yourpersonalinformationwhich we hold may be disclosed to suchparty or itsadvisors as part of any due
diligenceprocessforthepurposeof analyzing anyproposedsale orre-organization or transferred tothatreorganizedentity orthirdpartyand used forthe same purposes asyou haveagreedtounderthisAgreement.
8. YOUR RIGHTS
8.1 You are not required to provide any personal information requested by FEDTTM BILLIONAIRES.
However,
without that information, FEDTTM BILLIONAIRES may be unable to open an account for you, where the
information is requested in an
applicationform, or to provide you with any otherservices, information or assistanceyou have sought.
8.2 Dataprotectionlawgivesyouanumberofrightswhenitcomestopersonalinformationweholdaboutyou.
Thekeyrightsaresetoutbelow.MoreinformationaboutyourrightscanbeobtainedfromtheSCB. Under
certain circumstances, by law you have the rightto:
a. Beinformedinaclear, transparentandeasilyunderstandableway abouthowweuseyourpersonal
information andabout your rights. Thisis why INIFINOX is providing youwith the information in this
policy. If you require any further information about how we use your personalinformation, please let us
know.
b. Request an accessto your personal information (commonly known as a “data subject accessrequest”).
Thisenables you to receiveacopy ofthe personalinformation FEDTTM BILLIONAIRES holds
aboutyouand to check that FEDTTM BILLIONAIRES is lawfully processing it. FEDTTM
BILLIONAIRESmaycharge a nominalfee to coverthecost of verifying
theapplicationandlocating,retrieving, reviewing and copying any materialrequested.
c. Request acorrection of the personal information that FEDTTM BILLIONAIRES holds about you. This
enables youto have any incomplete orinaccurate information we hold about you corrected.
d. Request an erasure of your personal information. This enables you to ask FEDTTM BILLIONAIRES to
delete or remove personalinformation where there is no good reason for uscontinuing to processit(for
instance, we may need to continueusingyourpersonaldata to complywith ourlegalobligations).
Youalsohavetheright to ask us to delete or remove your personal information where you have
exercisedyourrighttoobject to processing (see below).
e. Object to processing of your personal information where FEDTTM BILLIONAIRES is relying on a
legitimate interest (or thoseofathirdparty) andthere issomethingaboutyour
particularsituationwhichmakes you want to object to FEDTTM BILLIONAIRES using your information
on this basis and FEDTTM BILLIONAIRES does not have a compelling legitimate basis for doing so
which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal
claim). You also have the right to object where FEDTTM BILLIONAIRES is processing your personal
information for direct marketing purposes.
f. Request a restriction for processing your personal information. This enables you to ask FEDTTM
BILLIONAIRES to suspendthe processing ofpersonalinformation aboutyou, forexample ifyouwant
FEDTTM BILLIONAIRES toestablish its accuracy orthe reason for processing it.
g. Request a transfer of your personalinformation to another party where you provided it to TRADE
INFINY and FEDTTM BILLIONAIRES is using it based on your consent, or to carry out a contract with
you, and FEDTTM BILLIONAIRESprocesses it
using automatedmeans.
h. Withdrawaconsent.InthelimitedcircumstanceswhereFEDTTM
BILLIONAIRESisrelyingonyourconsent(asopposed to theotherbasesset out above) to
thecollection, processingandtransfer ofyourpersonalinformation for a specific purpose, you
have the right to withdraw your consent for that specific processing at any time. Once FEDTTM
BILLIONAIRES has received notification that you have withdrawn your consent, FEDTTM
BILLIONAIRES will no longer process your information for the purpose or purposes you originally
agreed to, unless FEDTTM BILLIONAIRES has anotherlegitimate interestin doing so.
i. Lodge a complaint. If you think that FEDTTM BILLIONAIRES is using your information in a way which
breachesdata protectionlaw,pleasecontactusinthefirstinstanceusingthecontactdetailsprovided
in section 1.2 of this Policy. You also have the right to raise a complaint with your national data
protectionsupervisory authority (if you are in the United Kingdom,this will be the ICO).
9. UPDATING YOURINFORMATION
9.1 You may inform FEDTTM BILLIONAIRES at any time that your personal details have changed or that you
wish FEDTTM BILLIONAIRES to review, verify, correct or request erasure of your personal information,
withdraw your consent to the processing or requestthat we transfer a copy of
yourpersonalinformation to anotherparty. Please contact us via email at compliance@FedTtm
Billionaires.bs.
9.2 FEDTTM BILLIONAIRES will change or delete your personal information in accordance with your
instructions, except to the extent that we are required to hold your personal information for
regulatory or legal purposes, to provide you with the services you have requested or to maintain
adequate business records.
10. ACCESSING YOURINFORMATION
10.1 Under The Bahamas and United Kingdom data protection legislation, you have, subject to certain
exceptions, The right to obtain copiesof any personalinformationwhichFEDTTM BILLIONAIRESholds
about,thepurposes for which they are being or are to be processed, and the recipients or classes of
recipients to whom such information is or may be disclosed. You are entitled to inform FEDTTM
BILLIONAIRES of anyinaccuracy inyourpersonal information.
10.2 If you wish to access any personal information FEDTTM BILLIONAIRES may hold or wish FEDTTM
BILLIONAIRES to correct any
misinformation please notify us in writing using the address provided at the start of this policy. FEDTTM
BILLIONAIRES may charge a fee (details of which are available upon request) for providing access to the
information to cover the cost of verifying the application and locating, retrieving, reviewing and copying
any material requested.
10.3 FEDTTM BILLIONAIRES may need to request specific information from you to help to understand the
nature of your request, to confirm your identity and ensure your right to access the information (or to
exerciseanyof your other rights). This is another appropriate security measure to ensure that personal
information is not disclosed to any person who has no right to receive it.
10.4 Please consider your request responsibly before submitting it. FEDTTM BILLIONAIRES will respond to
your request as soon as possible. Generally, this will be within one month from the date your request
was received,ifthe requestis going to take longerto dealwith, FEDTTM BILLIONAIRES will let you know.
10.5 If you make a written request to us, we will also correct, delete and/or block personal information from
furtherprocessing ifthatinformation provesto be inaccurate.
10.6 Please note that pursuant to The Bahamas Data Protection (Privacy of Personal Information Act and
the United Kingdom Data Protection Act 1998) or the General Data Protection Regulation or any
other applicable laws and regulations, certain information may be exempt from disclosure or
FEDTTM BILLIONAIRES may be unable to disclose information you request.
11. COOKIES AND WEBSITE INFORMATION
11.1 FEDTTM BILLIONAIRES uses cookies (and other tools such as webpage counters or other analytics tools)
to gather information about your access to this website and other services we provide to you. Cookies
are small piecesofinformation which useauniqueidentification
tagandarestoredonyourdeviceasaresult of you using this website or other service we provide to you.
FEDTTM BILLIONAIRES uses this as necessary for our legitimate interestsinadministeringourwebsiteand
to ensure it operateseffectivelyandsecurely.
11.2 We,orthirdpartyadvertisers,mayalsousethisinformation toserveadverts onyou.Wherethoseadverts
are targeted, this may involve using website information and information we (or our third party advertisers)
have obtained from third parties. Thiswill notinclude information such asyour nameor contact details.
Whereouradvertsare displayedto youusingyourinformation, yourinformation is usedas necessaryforour
legitimate interests in marketing to you.
11.3 Wekeepthiswebsiteinformation aboutyouuntiltherelevantcookieexpires orisremovedby you.
11.4 When cookies are used by us, they collectstatistical and factual information about how you use our
services. Mostinternet browsersare setup toacceptcookies. If youdonot wishtoreceivecookies, you
maybe abletochangethesettings ofyourbrowser torefuseallcookies ortohaveyour computer notify
you each time a cookie issent to it, and thereby give yourself the choice whether to accept it or not.
However,thismayimpairthequalityoftheservicesthatweprovidetoyou inrelationtoyouraccount.
11.5 Ourwebsitemay,fromtimetotime,containlinkstothirdpartywebsites,plug -insandapplications.Clicking on
thoselinksorenablingthoseconnectionsmayallowthirdparties tocollector sharedataaboutyou. We do not
controlthese third party websites and are not responsible for their privacy statements. When you leave our
website,we encourageyou toread the privacy policy of everywebsite youvisit.
12. CONTENT INFORMATION
12.1 ThisisinformationaboutyouwhichyouprovidewhenyoupostcontentonFEDTTM BILLIONAIRES’s
website,social media andanyotherTRADE
INFINY’ssites.Thismayincludereviews,photographs,videosandothercontent.
12.2 We may display and publish thisinformation on our platforms as part of our contract with you or as
necessary forourlegitimate interestsinproviding contenttoourusers.
12.3 Thisinformation is keptfor aslong as you have anaccountwith us andmay be retainedanddisplayed
indefinitely after you close your account.
13. INFORMATIONCOLLECTED ATOURPREMISES
13.1 VISITOR INFORMATION
FEDTTM BILLIONAIRES collects information about visitors to our premises. FEDTTM BILLIONAIRES may
recordinformationon your visit, including the date and time, who you are visiting, your name, employer,
contact details and vehicle registration number. If you have an accident at our premises, thismay include
a record of youraccident.
13.2 CCTV
FEDTTM BILLIONAIRES may operate CCTV at our premises which may record you and your activities. We
display notices to make it clear what areas are subject to surveillance. We only release footage following
a warrant or formal request from law enforcement, or as necessary in relation to disputes.
13.3 FEDTTM BILLIONAIRES usesthisinformation as necessary for our legitimate interests in administering
your visit, ensuring site security and visitorsafety, and administering parking.
14. STORAGE OFINFORMATION
14.1 FEDTTM BILLIONAIRES’s office headquarters are based in the United Kingdom with a main data centre
located in the United Kingdom also. However, where required to perform our contract with you or for
our wider business purposes, theinformation that we hold aboutyoumay be transferred to, and
stored at, a destination outside theUnited Kingdomand the EU.
14.2 Youacknowledgeandagreethatyourpersonalinformationmaybetransferredwithinoroutsidethe The
Bahamas, United Kingdom and European Economic Area(EEA). Youagree thatwe willbe permitted, ifso
required, to furnish relevant information concerning or your Trading Account(s) to any person who we
believe to be seekingareferenceorcreditreferenceingoodfaith.Theinformationwesharemayaffect your
ability to obtain credit. Please note that FEDTTM BILLIONAIRES only transfers personal information to
organizations outside The Bahamas if FEDTTM BILLIONAIRES has assessed the organization as having
appropriate controls and safeguardsin place to protect your personal data.
14.3 Somecountriesor organizationsoutside of The Bahamas,United Kingdomandthe European Unionwhich we
may transfer your information to will have an “adequacy decision” in place, meaning The Bahamas
considers them to have anadequate data protection regime in place. Data may be transferred to,stored
andprocessed incountrieswhich donotoffer“adequateprotection” forthepurposesofDirectivesofthe
SCBforanypurposerelated to theoperation of your Account. Such purposesinclude theprocessingof
instructions and generation of confirmations, the operation of control systems; the operation of
management information systems; the carrying out of such credit and identity checks as we may deem
necessary or desirable; and allowing staff of any of our Affiliates who share responsibility for managing your
relationshipfromotherofficestoview informationaboutyou.Youagreethatwhere itisnecessary for the
provision of these or other Services to you, we may transfer your information to persons who provide
services to FEDTTM BILLIONAIRES, including where those persons may be outside the EEA. You consent
to FEDTTM BILLIONAIRES’s processing and disclosing such information in accordance with FEDTTM
BILLIONAIRES’s Privacy and Security Policy published on FEDTTM BILLIONAIRES’s website(s), as may be
updated from time to time.
14.4 If we transferdata to countries ororganizations outside of The Bahamas thatdoes nothave anadequate
dataprotection regime in place, we willensure thatappropriate safeguards(forexample, model clauses
approved by the EU or a data protectionauthority) are put in place where required. To obtainmore details of
these safeguards, please contact us.
15. DATASECURITY
15.1 FEDTTM BILLIONAIREStakessecurityveryseriously and
adoptsindustryandinformationsecuritybestpracticesto protect your personal information and ensure it
is not accessed by unauthorized persons. Measures include encryption
ofdataduringtransmission,strong authentication mechanisms and secure access to machines and
data.
15.2 FEDTTM BILLIONAIRES has put in place appropriate internal security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
In addition, FEDTTM BILLIONAIRES limits access to your personal information to those employees,
agents, contractors and other third parties who have a business need to know. They will only process
your personal information on FEDTTM BILLIONAIRES’s instructions and they are subject to a duty of
confidentiality.
15.3 TRADE INFINYhas put in placeprocedures to
dealwithanysuspecteddatasecuritybreachandwillnotifyyou and any applicable regulator of a
suspected breach where necessary.
16. RETENTION OFINFORMATION
General retentionpolicy
16.1 To determine the appropriate retention period for personal information, we consider the amount, nature,
ands sensitivityof thepersonalinformation, the potential risk of harm from unauthorized use or disclosure
of yourpersonalinformation, thepurposesforwhich we processyourpersonalinformation andwhetherwe
canachievethosepurposesthroughothermeans, andtheapplicablelegalrequirements.
16.2 Generally,FEDTTM
BILLIONAIRESwillkeepyourinformationforaperiodoffive(5)years.Insomecircumstances,it
maybe
necessary to keepyour information forlonger than thatinorder to fulfilthe purposes we collected itfor,
includingforthepurposes ofsatisfyinganylegal,accounting,orreportingrequirements.
Legal Claims
16.3 Where FEDTTM BILLIONAIRES considers there to be a risk to defend or bring legal claims, FEDTTM
BILLIONAIRES may retainyourpersonalinformationasnecessaryforalegitimateinterestsinensuringthat
FEDTTM BILLIONAIREScan properly bring or defend legal claims. FEDTTM BILLIONAIRES may also need
to share this information with insurers or legaladvisers. How long FEDTTM BILLIONAIRES keeps this
information for will depend on the nature of the claim and how long FEDTTM BILLIONAIRES considers
there to be a risk that we willneed to defend or bring a claim.
16.4 In some circumstances FEDTTM BILLIONAIRES may anonymize your personal information so that it can
no longer be associatedwith you, in whichcase FEDTTM BILLIONAIRES may use such information
withoutfurthernotice toyou.
17. YOURCONSENT
17.1 Please read the following carefully to understand our views and practices regarding your personal data
and how we will treat it. By accessingthis website or otherservice we provide to you, you consent
toFEDTTM BILLIONAIRES collecting, maintaining, using and disclosing personal information about you
and provided by you or by another person as described above.
18. AMENDMENTS TOPOLICY
18.1 FEDTTM BILLIONAIRESmaymakechanges to this Privacyand Security Policyfrom time to
timeforanyreasonand will notify you of such changes by posting an updated version of this policy on
this website or where appropriate, byemail.
18.2 Youareresponsibleforregularlyreviewingthis Privacyand Security Policyand if youusethiswebsite orother
serviceweprovidetoyouafteranychangesarepublished,anysuchuseshallconstitute your agreement to
thosechanges.
