This Policy provides data subjects with information on how IC Markets Ltd collects personal data, what they do with it and with whom it may be shared. This privacy notice has been drafted in compliance with the requirements of the Data Protection (Privacy of Personal Information) Act, 2003, Statute Laws of The Bahamas (as may be amended from time to time) (“DPA”).

We ask that you read this privacy notice carefully as we would like to inform you that your privacy on the internet is of crucial importance to us and it also contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are?

IC Markets Ltd (“us”, “our” or “we”) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the DPA which applies across the Commonwealth of The Bahamas, and we are responsible as “controller” of that personal information for the purposes thereof.

Data Controllers and Contracting Parties

IC Markets Ltd will be the controller of your personal data provided to, or collected by or for, or processed in connection with our services and regulated activities.

Whether information has to be provided by you, and if so why.

The provision of “Your Data” is required from you to enable us to provide our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

Information collected by us.

In the course of your registration as a client, signing up for a demo or a live account with IC Markets Ltd or filling in any form on our Website, subscribing to our services, news or offers, marketing communications or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service related and/or legal purposes.

We will limit the collection of personal information to what is necessary to administer our business and carry out our regulated activities in an effort to provide you with superior service,

Information that you provide to us directly:

• Personal information, such as names, addresses, personal registration number, national identification number, passport number and email addresses etc (“Personal Information”), and
• Financial Information, trading experience and employment information for appropriateness assessment will also be collected.

However, the meaning of data “provided to” IC Markets Ltd is not limited to this. It is also personal data resulting from observation of your activities (i.e., were using a device or service).

This may include:

• History of website usage or search activities, details of your visits to our Website including, communication data;
• Traffic and location data;
• Website traffic pattern information, including IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This kind of information is only used in masked or aggregated form, which means that the individual user will not be recognisable. These data do not identify any individual.
• Communications between you and IC Markets Ltd via Live Chat, email, or telephone call.

Your e-mail address may be used by IC Markets Ltd in relation to its products and services (including any marketing campaigns related to these products or services). If you do not wish to receive such marketing material and marketing communications, you can opt-out at any time by clicking on “unsubscribe” or by sending an email stating so to dpo@icmarkets.bs.

The type of data collected and purpose of collection.

The type of data we collect along with the purpose for collection is listed below:

Personal data type:	Purpose:
Personal information such as gender, name, date of birth and address	To meet our anti-money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.
Contact information (email address and phone number)	In order to send you correspondence in relation to the services provided and to fulfil our regulatory and compliance obligations.
Employment information, financial information	In order to comply with KYC obligations and in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services.
Ethnicity, citizenship and social security numbers or national identity and passport	In order to comply with KYC and regulatory trade reporting and other AML obligations.
Proof of photo ID, address verification	In order to comply with KYC and regulatory trade reporting and other AML obligations.
Unique device number (IP address) and device information including version of web browser you use.	When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.
Financial sanctions and credit header information	In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions or political interests leading to us making decisions based on the results of these checks.

How we use your personal information

We use information held about you in the following ways:

• To ensure that the content in our website is presented to you in the most effective manner and to improve the content of our website;
• To communicate with you and contact you and to provide you with products and services that you request from us or, where you have considered to be contacted, for products and services that we feel may be of interest to you;
• Managing and administering the products and services provided to you;
• Keeping you updated as a Client in relation to changes to our services and relevant matters;
• Provide, improve, test and monitor the effectiveness of our Services.
• Develop and test new products and features.
• Monitor metrics such as total number of visitors, traffic and demographic patterns.
• Diagnose or fix technology problems.
• To carry out our obligations arising from any contracts entered between you and us.
• We may also use your data or permit selected third parties and our processors to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email.
• To notify you about updates to the website.
• To send out newsletters or information about other opportunities that we believe will be of interest to you. We will only send this to you if you have indicated that you wish to receive such information and we will respect your wish not to do so if you communicate such wish to us. You can opt-out receiving marketing communications at any time if you do not wish to receive such marketing material by clicking on “unsubscribe” or by sending an email request to dpo@icmarkets.bs.
• To promote safety and security. We use the information we have to help verify accounts and activity, and to promote safety and security on our regulated services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using teams of IT specialists, automated systems, and advanced technology such as encryption.

Who we share your personal information with?

We will not rent or sell your information to third parties outside of IC Markets Ltd (or the group of companies of which IC Markets Ltd is part of) without your consent. We also impose strict restrictions on how our processors can use and disclose the data we provide. Here are the types of third parties we share information with:

• Service providers and other partners: We transfer information to service providers (processors), and other partners who globally support our business, such as providing technical infrastructure services, trading platforms analysing how our Services are used such as measuring the effectiveness of ads and services, providing client service and support, client on-boarding, client identification verification, including PEPs and sanctions, conducting marketing communications and design, services related to our website management, services related to software and business development services.
• Measurement and Analytics Services: Partners who use our analytics services like Google Analytics (Non-Personally Identifiable Information Only). We do not share information that personally identifies IC MARKETS LTD, with company registration number 76823 C, is authorised and regulated by the Securities Commission of the Bahamas with license number SIA-F214 and its Head Office is located at the Balmoral Corporate Centre, Unit H First Floor, Sandford Drive, New Providence, Nassau, Bahamas. you (personally identifiable information is information which includes your name or email address that can by itself be used to contact you or identify who you are) with advertising, measurement or analytics partners.

IC Markets Ltd does extensive due diligence before choosing processors assuring that they provide sufficient safeguards, in particular in terms of expert knowledge, data governance, data security, cyber resilience, reliability and resources to implement technical and organisational measures in such a manner that processing will meet the requirements of DPA and ensure the protection of the rights of the data subject.

The adherence of the processor to an SLA Contract is used as an element to demonstrate compliance with the obligations of the controller.

The carrying-out of processing by our processor it is governed by a contract or other legal act authorized and accepted under local or international laws, binding the processor to the controller.

This data sharing with our processor enables us to proceed with our regulated activities and duties for KYC processes in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services, providing support to clients, etc.

We will share personal information with law enforcement or other authorities if required by applicable law.

Cookies Data

We use cookies and similar technologies to provide and support our Services. When you use our website, we will use cookies to distinguish you from other users of our website.

For more information about cookies and how we use them, please read our Cookies Policy.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others by lawful request:

• We can respond to legal requests when we have determined that the response is required by law and/or by the appropriate Regulator in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards.
• Once we have a satisfactory determination it is necessary to: detect, prevent and address fraud, unauthorised use of the services or products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third parties about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information we receive about you (including financial transaction as data related to deposits and withdrawals) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

Your rights

Under the DPA you have a number of important rights. In summary, those rights include:

• Fair processing of information and transparency over how we use your personal information,
• The right to access personal data: via a Subject Access Request. Your request should be made in writing to dpo@icmarkets.bs.
• We may ask you for proof of identity before providing you with the data. There is usually no charge for such requests, however in limited circumstances we reserve the right to charge an administrative fee (and we will inform you in response to your request if that is the case).
• The right to request that your personal data is corrected if it is found to be inaccurate: require us to correct any mistakes in the information which we hold for you.
• The right to request that your personal data is erased where it is no longer necessary. In some circumstances this right may not apply, for instance, if there is some other compelling reason for us to keep or process your data (and we will inform you in response to your request if that is the case).
• Right to data portability: to receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party (another controller) in certain situations.
• The right to withdraw consent to processing at any time, where relevant i.e., where we are relying on your consent to process the data and not another legal reason for processing.
• The right to object at any time to processing of personal information concerning you for direct marketing.
• The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning them or significantly affects them.
• The right to object in certain other situations to our continued processing of your personal information.
• Otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

• email us at dpo@icmarkets.bs
• let us have enough information to identify you (e.g., account number, username, registration details),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates, including any account or reference numbers, if you have them.

Once a determination is made by us that the requested action will still allow us to comply with legal and regulatory requirements, we will consider taking the necessary action as requested.

Legal basis for processing personal data

We can collect and use your personal information for processing under DPA. There must always be a lawful basis for all processing of personal data (unless an exemption or derogation applies). We rely on contractual necessity. Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract to conduct regulated activities. When processing is necessary for the entry into, or performance of a contract with the data subject or in order to take steps prior to entering into a contract.

• Compliance with legal obligations. Processing is necessary for compliance with our legal obligation. IC Markets Ltd is required to comply with legal and regulatory policies.
• Legitimate interest. Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by IC Markets Ltd, and these interests or fundamental rights are not overridden by the interests, rights and freedoms of the data subject and that the processing would not cause unwarranted harm. For instance, it is a legitimate interest of IC Markets Ltd to process personal data on data subjects in order to expand the business, develop new business relations, prevention of fraud, maintaining the security of our systems if/when necessary, and enhancing, modifying or improving our services. The data subject must be given information on the specific legitimate interest if processing is based on this provision.

Keeping your personal information secure

Your Data is stored and kept confidential according to the laws relating to personal data and processing thereof applicable in the jurisdiction in which IC Markets Ltd with which you have signed up is located.

We have appropriate security measures in place to prevent personal information from being accidentally lost, misused, modification, disclosure or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

How long your personal information will be kept.

Data retention:

You can close your account any time, but for audit trail purposes, IC Markets Ltd shall hold personal data for a period of at least five years after closing the account in order for us to comply with our record keeping obligations under the Financial Transactions Reporting Regulations, 2018, Statute Laws of The Bahamas (as may be amended from time to time).

At the end of that period, we will delete all personal data relating to you, unless a legal requirement requires them to keep the data for a prolonged period of time, or Data Subject has expressly consented to their data being held for an extended period of time.

What happens in the event of a change of control?

If we sell or otherwise transfer part or the whole of IC Markets Ltd or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.

How to complain?

We hope that our Data Protection Officer, client support or compliance team can resolve any query or concern you raise about our use of your information.

The DPA also gives you right to lodge a complaint with a supervisory authority.

How to contact us?

If you wish to contact us with any queries, concerns or complaints, you can email us at dpo@icmarkets.bs

Changes to this privacy notice

This privacy notice was published in May 2019 and last updated in November 2023.

We may change this privacy policy from time to time, when we will inform you via our Website or via email.

Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).