Privacy Policy
OANDA GLOBAL MARKETS LIMITED
A. Policy Statement
OANDA Global Markets Limited (“OANDA”, “we” and “us”) and our affiliates respect customer
privacy and are committed to protecting it. The purpose of OANDA’s Privacy Policy is to explain
OANDA’s privacy policy and practices and how customer personal data (“Personal Information”)
is collected, used, disclosed and maintained by us. We will be the data controller of such Personal
Information and will process your Personal Information in accordance with our Privacy Policy.
The use and/or purchase of any of our services is subject to the applicable terms, the use of our
website is subject to our website terms of use and this Privacy Policy is incorporated into and forms
part of those terms.

B. Personal Information OANDA Collects
OANDA collects Personal Information about our customers from the following two main channels:
1. Website, Account and General Communications
In order to provide materials and services to you, when you visit our website, request materials
from us, register for events, or contract with us, we will collect data from you. We will receive
your information in these circumstances, as examples:•

Visiting and using our website•

Account Application Forms and other documents and data submitted by customers, suchas customer name, residential address, date of birth, employment information, investment
experience, annual income, and estimated net worth•

Customer Transactions with OANDA such as ordering our products/services, accountdeposits and withdrawals that require customers to provide bank account information•

Communications with OANDA including with customer service representatives and our
LiveChat or WeChat functions.
We refer collectively to these interactions as “Website Services”. We explain below how
we collect and use your information collected through the Website Services.

2. Trading Platforms
If you request access to any trading platform offered by us (or any third party provider that we
make available to you) and payment portal (the “Platform”), we will also collect information
about your use of the Platform. The information collected through the Platform will include
usage, performance, analytic and metadata and some of this may include your Personal
Information. This does not include any demo trading account (which falls within the scope of
our Website Services). In relation to trading platforms offered by a third party provider, these
may collect and use your information. This Privacy Policy does not extend to third-party apps

or add-ons (which may also collect your information) even if packaged by OANDA or offeredthrough the Website Services.
OANDA does not collect more Personal Information than is required to open and operate
customers’ accounts, and to comply with regulatory compliance and other legal obligations.
Website, Account and General Communications
What We Collect
We (or third-parties acting on our behalf) may collect your information, including your Personal
Information, when providing the Website Services including:
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Name
Email
Address
Phone Number
Country of Residence
Date of Birth/Age
IP address.

Platform
What We Collect
We (or third-parties acting on our behalf) may collect your information, including your Personal
Information, when providing access to the Platform including:
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Name
Email
Address
Phone Number
Country of Residence
Date of Birth/Age
Tax Identification Number
IncomeIncome Source
Level of liquid savings and investment
IP address
Employment Status
Employer Name
Industry
Trading Experience
Offences by way of a background check
Government Identifiers: National Identification Number/Passport Number & Passport
Expiry (which we electronically verify).

C. How OANDA Uses Personal Information
We may hold and retain information about you for various purposes based on different reasons.

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1. Website, Account and General Communications
Some of the information we collect from you we need to enable us to deliver the Website
Services to you in accordance with our terms, sometimes we are required by law andregulations to collect and process this information about you. At other times, we consider it isin our legitimate business interests to collect and process this information, taking into
consideration your privacy rights. We may use your information to:•

Fulfil your orders or respond to requests you make in connection with providing the services
under our terms with you
To provide you with a response pursuant to your request and your agreement with theapplicable terms, we will collect and use Personal Information including your name andemail address.

•

Provide our Website Services to you, including access to a demo account or support
through our LiveChat or WeChat functions.
In order to perform the Website Services under the contract between you and OANDA, wehave to collect certain Information from you such as your name and contact details. Without
this information, we may not be able to deliver the services which you request from us.

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Improve and develop the Website Services
We look for ways to innovate and advance our Website Services. We will use Information
about how you use the Website Services, including how you interact with various aspectsof the Website Services, the duration for which you use the Website Services and content
that is of interest to you, in order to do this. It is in our legitimate business interests to use
Personal Information in this way to develop improved Website Services.

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Send administrative information, changes to contract terms or policies
Where we make updates to terms and policies we are required under certain laws andunder our contract with you, to notify you of these changes. Other administrative
communications, may be necessary in order for us to perform our obligations under thecontract with you, or may be sent out in line with our legitimate business interests.

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Send marketing communications like product announcements, educational materials or
upcoming online or offline events, where you have not objected to receiving these or withyour consent where required. This may also include inviting you to participate in various
promotional activities and consumer research surveys
It is in our legitimate business interests to generate growth for our own business to ensure
we continue to generate development for our company and drive sales of our products andservices. We will carry out marketing campaigns and research surveys in accordance withother applicable laws.

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Research and analyse how our Website Services are used via cookies, web beacons andother similar technologies to personalise the Website Services. (For more information
about our use of cookies and your choices to opt-out of their use, see “Cookies” at section
I below.)
We use your information in our legitimate business to understand how you interact with ourWebsite Services and to deliver relevant content to you online.

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•

Diagnose and fix technical issues and monitor the security of our environments
We need to understand how our Website Services are performing in order to prevent andaddress any issues that may present themselves with regard to technical and security
operations. We may process your Personal Information for this purpose in our legitimate
business interests to protect the integrity of the Website Services•

To comply with any applicable law, regulation, legal process, or governmental request.

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For any other purpose disclosed to you in connection with our Website Services from time
to timeIf we intend to process your Personal Information for a purpose other than that set out
above, we will provide you with information prior to such processing.

It is also in our legitimate business interests to process your Personal Information to protect ourrights or property, or the security or integrity of our Website Services.
Third-Party Content. The Website Services may offer access to third party services. These
services may collect and use your information. This Privacy Policy does not extend to thirdparty apps or add-ons (which may also collect your Information) even if packaged by OANDA
or offered through the Website Services.
2. Platform
We collect Personal Information including payment details, as set out above, in order to provide
access to the Platform under the contract between OANDA and you. We are also required tokeep these payment details to comply with our own legal obligations.
We also collect and process usage data when you use our Platform (e.g. IP address, session
duration, activities undertaken on the Platform and other use data) (“Usage Data”) in order toprovide, maintain, and improve our Platform.
In addition, we collect and process data about our Platform, features or users in order to improve
the Platform (“Analytics Data”). Analytics Data may include information about the devices
operating the Platform (e.g. browser type/version, OS type/version, device type/version), orsuch other similar information about user configuration or operation of service features orfunctionality.
Whilst both Usage Data and Analytics Data may not contain information that we can use to
identify you in the "real world" (such as a name or address), we collect this data and store itagainst a uniquely assigned ID.
We may use automated decision making to analyse the transactions you conduct using the
Platform and create a profile for your usage. We may use algorithms to perform this analysis.
This assists the monitoring of transactions for fraudulent activity as well as reviews general
performance of our clients. If this raises concerns about fraudulent activity, we may take steps
to close the client account and liaise with authorities as is necessary.
How we use this Platform data
Usage Data. Specifically, OANDA may use Usage Data to:

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Evaluate whether currency trading is suitable for each customer•

Complete bank deposits and withdrawals•

Effect, administer or enforce transactions requested or authorised by the customer and•Maintain or service the customer’s account with OANDA.

Our lawful basis for using Usage Data is in order to take steps to enter into a contract with you
or as is necessary for the performance of a contract already in place between us.
Analytics Data. OANDA uses Analytics Data to help us better understand how our Platform isbeing used, make improvements, and develop new features, products and services. We may
use this data to:•

Better understand how our users configure and use our Platform•

Determine which configurations or practices optimise performance (e.g. best practices)•

Perform data analysis and audits•

Identify, understand and anticipate performance issues and the environmental factors that
affect them•

Other such business purposes relating to the operation, improvement, or development of
our Platform.

The use of this Analytics Data, for the purposes described in the above, is carried out pursuant
to our legitimate business interests, to develop, expand and improve our Platform offering.
We are sure to balance our legitimate business interests with your privacy rights and we takesteps in how we process and use Usage Data and Analytics Data to protect these.
Personal Information collected online may be combined with other information customers
provide to OANDA in hard copy or through the OANDA help desk.
Third-Party Content. The Platform may offer access to third party services, such as in the formof trading platforms created by third party providers such as MT4 or MT5. These services maycollect and use your information. This Privacy Policy does not extend to third-party apps or addons (which may also collect your Information) even if packaged by OANDA or offered throughthe Platform.

D. Disclosure of Customer Personal Information
OANDA may disclose Personal Information of current and former customers to affiliated and nonaffiliated third party entities in connection with our business (who may be located anywhere in theworld but where adequate safeguards are in place for the transfer), as set out further in the section
marked "Where do we store your Personal Information") including, without limitation:

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5•to OANDA’s service providers that perform services on OANDA’s behalf under writtenagreements which restrict use of Personal Information to the limited purposes for which itis provided to them and to refrain from further use or disclosure except as permitted by law.
This may include companies who perform background checks or identity verification,
infrastructure, data analysis, business intelligence, customer relationship platform
providers, marketing support services providers, consumer research service providers,cloud service providers, and IT service providers•

to communicate with credit reference and information agencies•

to OANDA strategic partners to permit them to assess your interest in Website Services,
including foreign exchange payments and international money transfers•

to OANDA affiliates, who are permitted to disclose and use the information only to theextent that OANDA may disclose and use the information under this Privacy 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, unauthorised transactions, claims or otherliability•

to government, regulatory or law enforcement agencies to the extent permitted or requiredby law, or to comply with applicable legal requirements•

to any FCA-regulated or PRA-regulated individual who is seeking to obtain a reference on
your account or persons we believe to be seeking a credit reference in good faith•

to monitor our services, whether provided by ourselves or a third party•

to comply with civil, criminal or regulatory investigations, or judicial process, summons or
warrant by appropriate authorities or•in the event of a proposed or actual reorganisation, merger, sale, joint venture, assignment,
transfer, or other disposition of all or any portion of OANDA’s business, assets or stock(including in connection with any bankruptcy or similar proceedings).

The client confidentiality obligations set out in our Privacy Policy do not and will not apply to, andin respect of, any confidential information required to be disclosed (by us or you) pursuant to any
applicable law, or the lawful request of any court of competent jurisdiction, government agency, or
regulatory body, provided in each case you (or we) notify and consult with us (or you) in advanceand as to the timing and content of such disclosure, except where applicable law prohibits us (oryou) from doing so.
Except as stated in this Privacy Policy, OANDA will not share Personal Information about any
present or former customer with any non-affiliated third party without the customer’s prior writtenconsent.

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E. How we secure your Personal Information
All information you provide to us is stored on our secure servers. Where we have given you (orwhere you have chosen) a password which enables you to access certain parts of our Website
Services and Platform, you are responsible for keeping this password confidential. We ask you not
to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although
we will do our best to protect your Personal Information, we cannot guarantee the security of yourdata transmitted to our Website Services and Platform; any transmission is at your own risk. Once
we have received your information, we will use strict procedures and security features to try to
prevent unauthorised access.

F. Where do we store your Personal Information
The data that we process in relation to you may be transferred to, and stored at, a destination
outside the British Virgin Islands (BVI) that may not be subject to equivalent data protection law. It
may also be processed by staff situated outside the BVI who work for us or for one of our suppliers.
We may transfer your personal information outside the BVI:•

In order to store it•

In order to enable us to provide goods or services to and fulfil our contract with you or thecompany you work for. This includes order fulfilment, processing of payment details, andthe provision of support services•

Where we are legally required to do so•

In order to facilitate the operation of our group of businesses, where it is in our legitimate
interests and we have concluded these are not overridden by your rights.

Where your information is transferred outside the BVI, we will take all steps reasonably necessary
to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal
adequacy mechanism, and that it is treated securely and in accordance with this Privacy Policy.
We may transfer your personal information to the following countries outside the BVI:•

Any member of our group, which means our subsidiaries, our ultimate holding company
and its subsidiaries, the details of which are set out in the table below, and for thesetransfers we use approved contractual clauses.
Group Member

Location

OANDA Global Corporation

United States

OANDA Corporation

United States

OANDA Business Information & Services Inc.

United States

OANDA (Canada) Corporation ULC

CanadaOANDA Asia Pacific Pte. Ltd.

SingaporeOANDA Japan Inc.

Japan

OANDA Australia Pty. Ltd.

Australia

OANDA Europe Ltd.

United Kingdom

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7•OANDA Europe Markets Ltd.

Malta (EU)OANDA Global Markets Ltd.

British Virgin Islands

OANDA Poland sp. zo.o.

Poland (EU)Our vendors, details of which are set out below, and for these purposes we use approved
contractual clauses:
Vendor Purpose

Location

Email Service Provider

United States

Cloud Data Storage

United States

Messaging Service Provider

United States

Chat Service for Customer Support

United States, Europe, China

Team Collaboration Software

United States, Australia

Customer Relationship Management

United States

Identity Verification

United States, Canada

Business Intelligence

United States

Marketing Support Services

United States

Funds Processing

United States, Canada

Consumer Research

United States

Customer Service

Philippines

Onboarding Processing

Philippines

G. How long we retain your Personal Information for
We retain Personal Information (a) in relation to the Platform, for as long as you have an accountwith us in order to meet our contractual obligations to you and for five years after that to identify
any issues and resolve any legal proceedings, (b) in relation to Website Services, for 12 months
unless such data is likely to relate to a contract you may/have entered into in the future, and subject
to any subject access requests you may make and (c) in relation to any data provided with consent
for research purposes, until such time when the data are no longer needed for the purpose forwhich they were first collected.
We may also retain aggregate information beyond this time for research purposes and to help us
develop and improve our services. You cannot be identified from aggregate information retainedor used for these purposes.
H. Your Data Subject Rights
Any concerns a customer may have regarding OANDA’s Privacy Policy or specific complaints
about how customer Personal 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.
You have the right under certain circumstances:•

to receive information about the processing of Personal Information concerning you. You
are entitled to access your Personal Information

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to request the rectification or erasure of your Personal Information held by us•

to object to the further processing of your Personal Information, including the right to object
to marketing•

to request that your provided Personal Information be moved to a third party.

Depending on the context of your request, such as erasure, we may not be able to provide youwith access to some or all of the Website Services and/or Platform, since we process yourinformation in order to provide you with such access.
Your right to withdraw consent:
Where the processing of your Personal Information by us is based on consent, you have the rightto withdraw that consent at any time by contacting us as per section L below.
How to exercise your rights
You can also exercise the rights listed above at any time by contacting us at privacy@oanda.com
If your request or concern is not satisfactorily resolved by us, you may approach your local dataprotection authority (to your habitual residence, your place of work, or where the alleged
infringement took place).

I. Cookies
Cookies are small text files placed in visitors’ computer browsers to store their preferences. The
Website Services, our Platform, and our third party partners, collect and store information that is
generated automatically as you use it, including your preferences and anonymous usage statistics.
OANDA collects information about your device and uses tracking mechanisms such as cookies to:(i) facilitate customer use of our website and mobile applications, (ii) enable customisation of ouronline services and website features, (iii) avoid customer re-entry of data, (iv) store customer
preferences for certain kinds of information, (v) enhance security measures, and (vi) gather data
about usage of our website and mobile applications for research and promotions.
OANDA uses cookies from third party service providers to facilitate website tracking and security
measures and may share the information collected with third parties acting as our service
providers, who are required to maintain the confidentiality of the information.
We use these cookies and other technologies on the basis that they are necessary for the
performance of a contract with you, or because using them is in our legitimate interests (where wehave considered that these are not overridden by your rights), and, in some cases, where requiredby law, where you have consented to their use.
We use the following types of cookies:•

Essential cookies. These are cookies that are required for the operation of our Website
Services and/or our Platform and under our terms with you. They include, for example, cookies
that enable you to log into secure areas of our Website Services and/or our Platform.

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Analytical/performance cookies. They allow us to recognise and count the number of visitors
and to see how visitors move around our Website Services and/or our Platform when they areusing it. This helps us for our legitimate interests of improving the way our Website Services
and/or our Platform works, for example, by ensuring that users are finding what they arelooking for easily.

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Behavioural cookies. These are used to recognise you when you return to our Website
Services and/or our Platform. This enables us, subject to your choices and preferences, topersonalise our content, greet you by name and remember your preferences (for example,
your choice of language or region).

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Marketing cookies. These enable you to experience more relevant online content and see
adverts which are aligned with your interests, as indicated by your activity on our site.
Customers can configure their browser preferences not to accept these 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 andservices of particular interest to individual customers. For more information on this practice or to
opt out, please visit https://www.aboutcookies.org.

J. Links to non-OANDA websites
The OANDA website may provide links to third-party websites for customer convenience andinformation. 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 fromOANDA’s. OANDA does not endorse or make any representations about third-party websites.
Any Personal 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 Personal Information. Some thirdparty companies may choose to share their
Personal Information with OANDA. That sharing is governed by the disclosing company’s privacy
policy.

K. Notification of Policy and Policy Changes
OANDA provides an initial notice of its Privacy Policy to customers at the time it establishes acustomer relationship and the Privacy Policy is dated and 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.

L. Contact Us:
We will never ask you for security information such as passwords over the phone or by email. If
you receive a call or email which you are not sure has come from OANDA, please contact us at
infosec@oanda.com.
We value our customers’ opinions. If they have comments or questions about our Privacy Policy,
they are invited to email us at privacy@oanda.com.

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