INTRODUCTION AND DEFINITIONS
THEFOREXHUB Limited t/a The Forex Hub ("we", "our" and "us") is committed to protecting and respecting your privacy.
By visiting www.theforexhub.com ("our site") you are accepting and consenting to the practices described in this policy.
Our site may, from time to time, contain links to and from partners', advertisers', affiliates' and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check their privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.
If you have questions about correcting or deleting your personal data please refer to section 3 below.
References in this policy to "data protection law" mean (as applicable) the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in England and Wales from time to time.
References in this policy to "data or "information" include "sensitive personal data" and "special categories of data" (as defined under data protection law) where applicable.
- Our details
- For the purposes of data protection law:
- the data controller for data you provide to us or that we collect about you will be us, THEFOREXHUB Limited of C/O Paris Smith LLP, London Road, Southampton, United Kingdom, SO15 2AE;
- in circumstances where we process data on behalf of Teachable (see paragraph 2.2.5 below for more information), Teachable is the data controller and we are the data processor.
- How we use your information
- The following sections set out why we are processing your information, what information we collect, the legal basis for and duration of our processing of your information, who your information will be shared with and (if applicable) where those recipients are based.
Which information do we process and for what purpose?
- We process the following information from you:
- Information you give us. This is information about you that you give us by filling in forms on our site or by contacting us using other means. It includes information you provide when you request marketing information, enter a competition, promotion or survey and when you report a problem with our site or give feedback.
The information you give us may include your name, address, email address, phone number, date of birth, gender and personal description.
- We process information you give to us for the following purposes:
- to respond to your enquiries, including concerning our products and services, our site and applications to become an affiliate;
- to respond to communications from Teachable concerning your contract with Teachable; and
- to notify you about changes to our site, products or services.
- Information we collect about you. Like most other website operators, we collect non-personally identifying information of the sort that web browsers and servers typically make available. This includes technical information, such as your IP address and your login information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages.
- We process information we collect about you for the following purposes:
- to improve our site;
- to ensure that content from our site is presented in the most effective manner for you and for your computer; and
- to measure or understand the effectiveness of advertising we serve to you and others, and possibly to deliver relevant advertising to you on our site.
- Information obtained from or provided by third parties. If you subscribe to one of our courses through Teachable then Teachable will send us your name, email address and confirmation of the course you have subscribed to.
- We process information obtained about you from Teachable for administrative purposes. This includes where you have a query regarding our courses or if you wish to request a refund. With the exception of Teachable (who already has this information as they provided it to us), we do not share this information with any third parties.
- Where we discuss information about you with Teachable, we do so because it is necessary for the performance or administration of Teachable's contract with you for the supply of our course(s).
What are the grounds for processing your information?
- We are processing your data on the following grounds:
- where you are a subscriber (or potential subscriber) to one of our courses through Teachable, the processing is necessary for the performance of the contract between Teachable and you. This includes where you have instructed us to take pre-contractual steps, such as providing you with additional information about our courses, prior to you formalising the contract with Teachable (i.e. making payment); and
- the processing is necessary for achieving our legitimate interests of keeping records of recipients of our materials through Teachable for administrative purposes, including accounting, complaints handling and management of our intellectual property. In accordance with data protection law, we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information for these purposes and are satisfied that we are justified in processing your information in this way.
Duration and further processing
- We will store:
- the information about you which you provide to us; and
- information about you provided to us by Teachable,
for six years from date of receipt. This is so we can refer back to it in the event of a dispute or in case we need it for accounting purposes.
- If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so. This may be the case where, for example, there is a dispute or the potential for a dispute between us or that information is needed to administer a dispute between us and a third party (e.g. Teachable).
- We regularly review the durations for which we keep your information and endeavour to keep your information no longer than is necessary for our legitimate business objectives.
Who is your information shared with?
- Your personal information is not shared with anyone except where:
- we are required to do so to comply with the law;
- to protect our rights, the rights of our employees, agents, customers or third parties; or
- we communicate with Teachable to administer your subscription to one of our courses, e.g. to resolve a complaint you have made.
- We may share anonymised, pseudonymised and non-personal information with sub-contractors engaged by us to help us operate our site, or to advertisers who we permit to place relevant adverts on the site, and to analytics and search engine providers that assist us in the improvement and optimisation of our site.
- To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.
Automated decision making
- We do not make automated decisions about you based on your information.
- Your rights
- Under data protection law you have the following rights:
- if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by notifying us using the details set out in section 8 below. In the case of consent to marketing communications, you will additionally be able to withdraw your consent by following the opt-out procedure set out in each communication. The lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent;
- the right to access a copy of your information which we hold. This is called a 'subject access request'. Additional details on how to exercise this right are set out in section 5, below;
- the right to object to processing of your information where it is likely to cause or is causing damage or distress;
- the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the details set out in section 8, below;
- the right to object to decisions being made about you by automated means. Your information is not subject to automated processing but we will inform you if this changes;
- the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate; and
- the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law.
- From 25 May 2018 you will have the following additional rights under data protection law:
- enhanced rights to request that we erase, rectify, cease processing and/or delete your information; and
- in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other services. This right is called 'data portability'. Additional details on how to exercise this right are set out in section 5, below.
- You also have the general right to complain to us (in the first instance) and to the Information Commissioner's Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in section 8, below. The Information Commissioner's Office website is www.ico.org.uk.
- For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner's Office (www.ico.org.uk).
- ACCESS TO INFORMATION
- Under data protection law you can exercise your right of access by making a request to receive copies of the information we hold on you. Prior to 25 May 2018 there is a £10 fee for making the request. From 25 May 2018 you will:
- no longer have to pay a £10 fee but we will be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the information we hold about you if your request is clearly unfounded or excessive; and
- in certain circumstances, be entitled to receive the information in a structured, commonly used and machine readable form.
- Requests should be sent using the contact details set out in paragraph 8 below. We will need to see proof of your identity before processing your request.
- Data security
We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our site or otherwise to our servers (such as by email). Any such 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.
- sent by post addressed to THEFOREXHUB Limited, C/O Paris Smith LLP, London Road, Southampton, United Kingdom, SO15 2AE; or
- by email to [email protected]