Privacy Policy

Privacy Policy

The name “Velocity” refers to the Velocity Trade Holdings Ltd. (“Velocity Trade” “We” “Us“) and its worldwide affiliates and subsidiaries. This Privacy Policy sets out how Velocity may collect, use or disclose information about you when you interact with Velocity and your associated rights. In this Privacy Policy “the Client”, “you” or “your” refers to you, being the person interacting with us and submitting completed online applications on the Website.

By signing the Application Form or selecting ‘accept/agree’ online, you consent to the matters outlined in the Privacy Policy.

Personal Information

Regulatory requirements governing our products and services make it necessary for Velocity to collect certain information from you. If you complete the Application Form; trade online with us; or communicate with us (which includes the use of our website, speaking to us on the telephone or sending us correspondence or information by post or email to us), you will be supplying Velocity with, and Velocity will be collecting, information that is “Personal Information”.

In Australia, Velocity Trade Limited will deal with your personal information in accordance with the Australian Privacy Principles issued in accordance with the Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (collectively, “Privacy Act”) with the Australian Privacy Principles (“APPs”). Personal information is defined in Section 6 of the Privacy Act as “information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not.”

If you are in Europe, Velocity Trade International Ltd. is the controller and processor of data for the purposes of the General Data Protection Regulation (GDPR) and the Data Protection Act (DPA).

In South Africa, Velocity Trade Financial Services (Pty) Ltd is deemed to be a responsible party in terms of the Protection of Personal Information Act 4 of 2013, as amended, consolidated or re-enacted from time to time, including all schedules and regulations thereto (“the POPI Act”), and Velocity is obliged to comply with the provisions of the POPI Act.

Common examples of personal information are an individual’s name, signature, photo, address, telephone number, date of birth, medical records, bank account details and commentary or opinion about a person. Velocity may also need to collect other personal details (such as financial information, gender and marital status) and other information from which you can be identified.

Unless required by law or where you consent for us to do so, we generally do not collect sensitive information about you. We will not collect sensitive information about you where this is expressly prohibited by local law. Sensitive information includes information relating to:

• Biometric and health information;
• Criminal convictions;
• Membership of professional or trade associations or unions;
• Political affiliations or views;
• Race;
• Religious beliefs;
• Sexual orientation and sexual life;
• Information about your affiliation with certain organisations, such as professional associations.

Additional material Information required for fulfilling most financial requests and applications includes:

• Information establishing your identity, such as your name, address, phone number, title, business phone number, email address, date of birth, social insurance number or social security number (for tax purposes), and account numbers;
• Information to authenticate your identity, such as knowledge-based information (i.e. username, password and account information), biometric information (i.e. signature, fingerprint and voiceprint), device information (i.e. device model, browser type, IP address, security cookie and approximate physical location of device);
• Information related to transactions arising from your relationship with and through us, and from other financial institutions, including point of sale details;
• Information you provide on an application for the provision of our products and services, such as your annual income, place of employment, investments, account balance, financial liabilities, transaction history;
• Information you provide during communication with us which may include family details, life events, goals and your opinions and issues you may have encountered;
• Information about financial behaviour such as your payment history and credit worthiness;
• Information about your health may be collected for insurance products and services;
• Information pertaining to business clients will include your business name, address, phone number, email address, industry type, financial status and detail(s) on the owner(s), operator(s) and director(s);

Collection and disclosure of personal information

We may collect and use your Personal Information for the following purposes:

• Identification and verification of certain persons to comply with anti-money laundering and counter-terrorism financing (“AML/CTF”) obligations;
• Assessing your application; assessing the credit and other exposure that Velocity Trade has to you (see below for more details regarding the use of your Personal Information for credit checking purposes);
• Marketing of similar products and services; determining future product and business strategies and to develop Velocity Trade’s products and services; communicating with you in relation to Velocity Trade’s products and services including in relation to any Transaction made and/or your Account;
• Providing products and services to you; and Velocity Trade’s hedging arrangements or Transactions with Hedging Counterparties.

When we communicate with you for the above purposes, you consent to receiving communications from us in any form, including email. Your Personal Information may be disclosed to entities associated with Velocity Trade, Velocity Trade’s counterparties or third party product or service providers for the above purposes. It may also be disclosed to any financial institution nominated by you and may be disclosed to your financial adviser if you request so in writing. Your personal information may be transmitted through, stored or processed in countries other than your region, in which case the information is bound by the laws of these countries.

These countries may include, but not limited to, Australia, Canada, European Union member states, New Zealand, South Africa, and the United Kingdom.

We will not disclose your Personal Information to any other third party except where required to or permitted to by law, where you have authorised us to do so, or where disclosure is connected to the purposes for which the information was collected. You can, by contacting us, instruct us not to disclose your Personal Information to companies related to us. If you do not wish to be kept informed of Velocity Trade’s marketing or promotional activities electronically, please contact us via email.

We may use service providers to perform specialized services on our behalf such as marketing, mail distribution or data processing. Our service providers may at times be responsible for processing or handling personal information. They are provided only the information necessary to perform the services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and security practices.

We do not sell Personal Information to other organizations.

Access to your information is restricted to authorized employees who have a legitimate business purpose for using it. Unauthorized use and or disclosure of client information by an employee of Velocity is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.

While the information we ask you to supply is not required by law, we may not be able to assess your application if the information is not supplied.

Anti-money laundering and Know Your Client information

In accordance with the Anti-Money Laundering and Counter-Terrorism Act 2006 (Cth) (“AML Act”), Velocity Trade has an obligation to collect information about and verify the identity of its clients and certain individuals, this includes any directors, members and ultimate beneficiary owners of a company. This information is referred to as Know Your Client information or KYC information which may include your full name, address, date of birth, email address and contact details. Velocity Trade will carry out its customer identification and verification procedures in accordance with the Privacy Act 1988 (Cth).

Information verification and database checks

Velocity Trade may use the services of a third-party identification verification service provider (such as a credit reporting agency or government database) to conduct a verification check on you which will be used for verification of the identification information that you have provided. The third-party verification service providers used to verify your identification details include:

• Credit data files held by a credit reporting agency (for identification purposes only, and not a credit check).
• Publicly available information such as the electoral roll
• Information held the official record holder via third party systems, such as Commonwealth and State government departments

As a result of Velocity Trade’s enquiry to that/those credit reporting agencies and databases:

• That/those credit reporting agencies may provide Velocity Trade with information, including Personal Information, about you;
• Velocity Trade may provide Personal Information to the credit reporting agencies and the credit reporting agencies will hold the Personal Information on their systems and use it to provide their credit reporting service, which may include providing the Personal Information to third parties that may use the credit reporting agencies’ services; and
• Velocity Trade may use one or more credit reporting agencies’ services in the future for purposes related to the provision of Velocity Trade’s services to you. This may include using that/those credit reporting agencies’ monitoring services to receive updates if any of the information held about you changes.
• If you fail to perform your obligations under the Client Agreement or any transaction, information about that default may be given to one or more credit reporting agencies and/or databases, and the credit reporting agencies may give information about your default to other customers of that/those credit reporting agencies.
• Velocity Trade will not provide any credit reporting agencies with information regarding the specific Transactions that you enter into.

Website

When you visit our website, we (or our service providers in connection with the website) may use technology to collect information to assist us with administering the website and with enhancing the content and facilities on the website. An example of the technology that we use is “cookies”.

A “cookie” is a packet of information placed on a user’s computer by a website. The purposes for which cookies are used on this website may include:

• Enabling access to online services;
• Managing advertising – we may use advertising companies to deliver our online advertising. When you see one of our ads on a third party website, cookies are sometimes used to collect information about what pages you visit and the type of software you are using; and
• Monitoring web traffic – we may use tracking companies to gather information about how people are using the Velocity Trade website, this information includes time of visit, pages visited, and some system information about the type of computer you are using.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from this website or linked websites then you may not be able to gain access to all of the content and facilities on this website.

HYPERLINKS

Our Website may contain links to and from the websites of our advertisers and/or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please familiarise yourself with these policies before you submit any Personal Information to these websites.

CHANGES TO PRIVACY POLICY

The Website and/or any other information displayed on the Website may change from time to time. As a result, at times it may be necessary for Velocity to make changes to the Website and this Privacy Policy. Velocity reserves the right to update or modify its Website and this Privacy Policy at any time and without prior notice to you. We will request your consent should any update or modification of the Website or Privacy Policy adversely affect your rights set out herein.

Please review this Privacy Policy periodically and especially before you provide any Personal Information to us. Your continued use of the Website, after any changes or revisions thereto or to this Privacy Policy, shall indicate your agreement with the terms of such revised Privacy Policy.

Your Rights

Velocity takes steps to ensure that appropriate standards of privacy practice and security are applied when we handle personal information. Regardless of our your jurisdiction, you have rights to access and to correct the Personal Information we hold about you.

As a Velocity client you will receive periodic access to information in the form of transaction activity records, including account statements and trade confirmations. This information is routinely available to you through mailings, secure online sites and smart phone application.

You can contact us by phone, fax or email including requesting access to your information. In normal circumstances, we will give you full access to your information. However, there may be some legal or administrative reason to deny you access, in which case we will tell you of that reason. Further, we may impose a charge to give you full access where your request requires the compilation of information that has been archived or is significant in volume.

If you have any concerns about the accuracy of your Personal Information, please contact our Compliance team in your local jurisdiction.

Australia & New Zealand

Under the Privacy Act you have rights to access and to correct the Personal Information we hold about you.

Your Personal Information will be held by us at Velocity Trade’s offices, 95 Pitt Street, Suite 9.01, Sydney, Australia 2000, and Buddle Findlay, 18/188 Quay Street, Auckland 1140, New Zealand. Your Personal Information will be retained only for as long as necessary to fulfil the purposes for which it was collected.

If you have any questions about this Privacy Policy, have a request relating to your Personal Information, or would like to lodge a complaint regarding breach of our Privacy Policy by a third-party, please contact our regional Compliance Officer as follows:

• Email: ausnzcompliance@velocitytrade.com,
• Phone: +64 9 964 0781

Canada

If you are client of Velocity Trade Capital Ltd. or Velocity Trade Foreign Exchange Services Ltd. in Canada your Personal Information will be held by us at Velocity’s offices located at 100 Yonge Street, Suite 1800, Toronto, Canada. Your Personal Information will be retained only for as long as necessary to fulfil the business purposes for which it was collected.

If you have any questions about this Privacy Policy, have a request relating to your Personal Information, or would like to lodge a complaint regarding breach of our Privacy Policy by a third-party, please contact our Privacy Officer in Canada:

Andrew Morton, Privacy Officer
100 Yonge Street, Suite 1800
Toronto, Canada
M5C 2W1

Email: andrew.morton@velocitytradecapital.com
Phone: (416) 640 -0590
Fax: (416) 926-1641

European/UK residents and or citizens

If you are in Europe, you have the following rights pursuant to GDPR and DPA:

• Access your data;
• Correct or rectify your data;
• Delete your data subject to applicable law;
• Have your data processed only in accordance with applicable law;
• In certain circumstances to data portability and copies of your data to be moved to another controller;
• Object to our processing your data otherwise than in accordance with the law;
• Withdraw any consent to our processing your data at any time; and
• You have the right to lodge a complaint to the Information Commission’s Office if you believe that we have not complied with the GDPR or DPA with regard your personal data and not responded satisfactorily to your data requests.
• Your personal data will be stored for a period of 5 years from the date in which our business relationship ceased.

If you are a European resident, you can also contact one of the EU data protection regulators here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

If you have any concerns as to how your data is processed you can contract Stephen Corker (steve.corker@velocitytrade.com) and Will Hutson (william.hutson@velocitytrade.com), who are the persons within Velocity who have responsibility for data protection in your region.

South Africa

Use of the Website and any electronic transaction concluded with Velocity Trade Financial Services (Pty) Ltd are governed by the laws of the Republic of South Africa. If the Client accesses this Website from locations outside of the Republic of South Africa, that Client is responsible for compliance with all local laws. If you are in South Africa, please feel free to contact us if you have any queries regarding Velocity’ Privacy Policy.

• Physical address: 200-on-Main, 200 Main Road, Claremont, Cape Town
• Telephone: on (021) 200 8800 during 0830 to 1700 on Monday to Friday
• E-mail: at support@za.velocitytrade.com

If your concerns are not resolved to your satisfaction, you may be able to escalate your complaint to an external dispute resolution process or to a regulatory authority.