A. Policy Statement
B. Categories of Client Information OANDA Collects
OANDA collects Client Information about our customers from the following sources:
Account Application Forms and other documents and data submitted by customers, such as customer or business name and business address;
Customer Transactions with OANDA such as subscription payments that require customers to provide payment information;
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 Client Information
OANDA may use Personal Information as necessary to:
effect, administer or enforce transactions requested or authorized by the customer, and
maintain or service the customer’s account with OANDA.
Client 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 Client Information about its customers or former customers to any third parties except as stated in this Policy. Client Information may be transferred across national borders for the purposes of data consolidation, storage and customer data management.
D. Disclosure of Customer Client Information
OANDA may disclose Client 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 Client 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 Client Information
F. Procedures to Safeguard Client Information
OANDA has implemented procedures to safeguard customer Client Information. OANDA restricts access to Client 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 Client 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 Self Service Portal. 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’ Client Information.
G. Retention of Client Information
OANDA only keeps Client 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 Client Information, it is either destroyed or made anonymous.
OANDA attempts to ensure the accuracy of the Client Information collected. OANDA records the dates when Client Information was obtained from customers and will periodically ask customers to review the Client Information OANDA has on file and to update any Client 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 Client 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.
OANDA uses tracking mechanisms, such as cookies, to: (i) facilitate customer use of our website and mobile applications, (ii) enable customization of our online services and website features, (iii) avoid customer re-entry of data, (iv) store customer preferences for certain kinds of information, and (v) gather data about usage of our website and mobile applications for research and promotions. Cookies stored on customers’ web browsers by OANDA cannot be read by, and are not shared with, any third parties. Customers can configure their browser preferences not to accept these cookies. OANDA uses third party tracking mechanisms to facilitate website and mobile applications tracking and may share the information collected with third parties acting as our service providers, who are required to maintain the confidentiality of the information. Customers can configure their browsers preferences not to accept third party cookies, however this may result in reduced functionality.
K. Links to non-OANDA websites
L. Sharing Information with Our Affiliates
OANDA may share Client 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 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.