A. Policy Statement
B. Categories of Personal Information OANDA Collects
OANDA collects Personal Information about our customers from the following sources:
- Account Application Forms and other documents and data submitted by customers, such as customer name, residential address, government issued ID numbers (such as social security numbers), date of birth, employment information, investment experience, annual income, and estimated net worth;
- Customer Transactions with OANDA such as account deposits and withdrawals that require customers to provide bank account information;
- Consumer Reports and other information OANDA receives from third party agencies;
- Communications with OANDA customer service representatives; and
- “Cookies” described in section J below.
OANDA will not collect more Personal Information than is required to open and operate customers’ accounts, and to comply with regulatory obligations.
C. How OANDA Uses Customer Personal Information
OANDA may use Personal Information as necessary to:
- positively identify and determine eligibility of customers opening accounts;
- evaluate whether currency trading is suitable for each customer;
- complete bank deposits and withdrawals,
- effect, administer or enforce transactions requested or authorized by the customer, and
- maintain or service the customer’s account with OANDA.
Personal Information collected online may be combined with other information customers provide to OANDA in hard copy or through the OANDA help desk. OANDA will not use or disclose or sell, rent or lease any Personal Information about its customers or former customers to any third parties except as stated in this Policy. Personal Information may be transferred across national borders for the purposes of data consolidation, storage and customer data management.
D. Disclosure of Customer Personal Information
OANDA may disclose Personal Information of current and former customers to affiliated and non-affiliated third party entities in the following cases:
- to OANDA’s business partners that perform services on OANDA’s behalf under written agreements which restrict use of Personal Information to the limited purposes for which it is provided to them and to refrain from further use or disclosure except as permitted by law;
- to OANDA affiliates, who are permitted to disclose and use the information only to the extent that OANDA may disclose and use the information under this Policy;
- in the ordinary course of business to OANDA’s attorneys, accountants and auditors;
- to persons holding a legal or beneficial interest relating to the customer’s account;
- to persons acting in a fiduciary, representative, or attorney capacity in relation to an account;
- to protect against actual or potential fraud, unauthorized transactions, claims or other liability;
- to government, regulatory or law enforcement agencies to the extent permitted or required by law, or to comply with applicable legal requirements; or
- to comply with civil, criminal or regulatory investigations, or judicial process, subpoena, summons or warrant by federal, state or local authorities.
E. Permission to Disclose Personal Information
F. Procedures to Safeguard Personal Information
OANDA has implemented procedures to safeguard customer Personal Information. OANDA restricts access to Personal Information to those OANDA employees who need to know that information in order to provide our products or services to them. OANDA maintains physical, electronic and procedural safeguards to safeguard Personal Information. OANDA protects customer account information by keeping it on the secure portion of its website, using firewalls and other security technology to protect its network and systems from external attacks, and by requiring customers to enter a unique user ID and password to access the fxTrade and fxTrade Practice systems. OANDA conducts periodic internal audits of its business practices and procedures, examining its confidentiality standards and information access, in order to best protect our customers’ Personal Information.
G. Retention of Personal Information
OANDA only keeps Personal Information on file for as long as it is required to provide customers with products and services, and to meet legal requirements. When OANDA no longer needs the Personal Information, it is either destroyed or made anonymous.
OANDA attempts to ensure the accuracy of the Personal Information collected. OANDA records the dates when Personal Information was obtained from customers and will periodically ask customers to review the Personal Information OANDA has on file and to update any Personal Information that may have changed.
I. Customer Recourse
Any concerns a customer may have regarding OANDA’s privacy practices or specific complaints about how customer 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.
K. Links to non-OANDA websites
L. Sharing Information with Our Affiliates
OANDA may share personal information described above with OANDA’s affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new products and services. OANDA’s affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in OANDA. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. OANDA’s affiliates maintain the privacy of your information to the same extent OANDA does in accordance with this Policy.
N. Contact Us
Regular Mail: OANDA Privacy Mailbox, 46th Floor, 140 Broadway, New York, NY 10005, U.S.A.