PROFESSIONAL ETHICS/CODE OF CONDUCT:
Lighthouse FX are committed to operating with a high level of professional integrity. As per section 9 of the 2010 Bribery Act and the Secretary of State for Justice’s guidance for commercial organisations, we implement procedures to counter corruption and bribery within our company. We adhere to all relevant laws within the jurisdictions that we operate. Our partners, associates, third parties, affiliates and customers are expected to uphold the same standards.
Encryption and Data Storage-
Sensitive client information and personal data is stored and backed up in a secure, encrypted system, to prevent unauthorised access.
A valid security key pass is required for anyone to enter our offices. No member of staff can be left unsupervised in the office without a member of senior management present. All computers are password protected and log-in credentials are changed regularly.
The premises is monitored by 24 hour CCTV surveillance.
All staff are subject to a Criminal Records Bureau (CRB) check prior to employment at Lighthouse FX. Our systems only allow individuals who have been specifically granted authorisation for the purposes of fulfilling their fundamental job role, access to customer information.
Lighthouse FX has a complete business continuity and disaster recovery policy to protect the company and its clients, which is tested and updated frequently.
These Site Terms tell you how you may use our website www.lighthousefx.co.uk (“our site”), whether as a guest or a registered user. Use of our site includes accessing, browsing or registering to use our site. By using our site, you confirm that you accept these Site Terms and that you agree to comply with them. If you do not agree to these Site Terms, you must not use our site.
Other applicable terms-
These Site Terms refer to the following additional terms, which also apply to your use of our site:
Please note, another set of Terms and Conditions will also apply if you purchase any services on our site.
We may revise these Site Terms at any time by amending this page. Please check this page from time to time to take notice of any changes We made, as they are binding on you.
Information about us-
www.lighthousefx.co.uk is a site operated by Lighthouse FX Ltd (“We”). We are registered in England and Wales under company number 11450998 and have our registered office at Saxon House, 27 Duke Street, Chelmsford, CM1 1HT.
Changes to our site-
We may update our site from time to time and may change the content at any time. However, please note that any of the content on our site may be out of date at any given time, and We are under no obligation to update it.
Accessing our site-
Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our site without notice. We will not be liable to you if for any reason our site is unavailable at any time or for any period.
You are responsible for making all arrangements necessary for you to have access to our site.
You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these Site Terms and other applicable terms and conditions, and that they comply with them.
Your account and password-
If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.
We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Site Terms.
If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us by emailing firstname.lastname@example.org or by calling 0203 967 8796.
Intellectual property rights-
We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws, trade marks and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.
You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licencors.
If you print off, copy or download any part of our site in breach of these Site Terms, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
No reliance on information-
The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.
We do not guarantee that our site, or any content on it, will be free from errors or omissions.
Although We make reasonable efforts to update the information on our site, We make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up-to-date.
Limitation of our liability-
Nothing in these Site Terms excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.
To the extent permitted by law, We exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied.
We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
· use of, or inability to use, our site; or
· use of or reliance on any content displayed on our site.
Please note that in particular, We will not be liable for:
· loss of profits, sales, business, or revenue;
· business interruption;
· loss of anticipated savings;
· loss of business opportunity, goodwill or reputation; or
· any indirect or consequential loss or damage.
· loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.
· content of websites linked on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.
Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any service by us to you, which will be set out in the Terms and Conditions.
We do not guarantee that our site will be secure or free from bugs or viruses.
You are responsible for configuring your information technology, computer programmes and platform in order to access our site. You should use your own virus protection software.
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities, and We will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
Linking to our site-
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link to our site in any website that is not owned by you.
Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.
We reserve the right to withdraw linking permission without notice.
If you wish to make any use of content on our site other than that set out above, please contact email@example.com or telephone 0203 967 8796.
Third party links and resources in our site-
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only.
We have no control over the contents of those sites or resources.
These Site Terms, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.
To contact us, please email firstname.lastname@example.org
Thank you for visiting our site.
This notice (“Privacy Notice”) describes our collection, use, disclosure, retention and protection of your personal information. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and bench-marking (see section 3 below for more information), direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.
1) Who we are
This Privacy Notice applies to all products, applications and services offered by Lighthouse FX (a company incorporated in England with company registration number 11450998 and whose registered office address is Saxon House, 27 Duke Street Chelmsford, CM1 1HT) and its affiliates, but excludes any products applications or services that have separate privacy notices which do not incorporate this Privacy Notice.
2) How we collect information
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described in section 11 below).
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.
Providing us with information about others-
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.
3) How we use your information
To the extent permissible under applicable law, we use your information to:
To the extent permitted by applicable law, we retain information about you after the closure of your account, if your application is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
You can manage your privacy settings within your browser or our applications and services (where applicable).
In addition to the purposes described in this section 3, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 5 and 6 of this Privacy Notice provides further details on how we will do this.
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Data analytics and bench-marking-
We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymous basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.
You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at email@example.com to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.
4) Sharing your information
We may share your information with
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties, but this will not include information that can be used to identify you.
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. We will not share your information with any third parties unless necessary in order to uphold our duties and services to you as our customer. If you wish to exercise these rights you can do so by sending us an email to firstname.lastname@example.org. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Third party platform advertising-
Where you respond to communications we post on third-party platforms (such as Facebook, Google and Twitter), we may also share your information with those third parties in order to serve targeted advertising/content to you via the relevant third party platform based on your profile/interests. Your information is used by the third-party platform provider to identify your account and serve advertisements to you. You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult the third party’s help/support center for more information.
6) Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.
We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
7) Changes to this privacy notice
We may change this Privacy Notice from time to time. However, we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website. This policy was last updated on the 11th March 2019.
8) Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information, but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.
If you believe your account has been compromised, please contact us at email@example.com or via telephone on 0203 967 8796.
9) Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.
Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers which are hosted in the United States.
We may use service providers based outside of the EEA to help us provide our website, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Notice. Such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.
10) Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third-party sites or services and we encourage you to read the privacy notices appearing on those sites or services.
Our websites, applications or services may enable you to share information with social media sites or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third-party social media account(s) to manage what personal information you enable us to access from that account.
11) Cookies, analytics and traffic data
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don't collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.
These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Web beacons and parameter tracking
We also use similar software known as web beacons to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of any products or services purchased. These web beacons collect limited information which does not identify individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.
IP address and traffic data-
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.
How to disable cookies-
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.allaboutcookies.org/ website.
12) Further information
If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please send an email to firstname.lastname@example.org for the attention of the Data Protection Officer.
CUSTOMER COMPLAINTS PROCEDURE:
We would like to hear from you if you have a complaint about our services or our staff. You can contact us by post or email at email@example.com. Please address all correspondence for the attention of the Compliance Manager.
To help us investigate and resolve the problem as quickly as possible, please provide the following information:
● Your name, address and client reference number
● A description of your complaint
● Your suggestion as to how we should resolve the issue
● Copies of any relevant documentation
● A contact number that we can use to reach you
We will work with you to resolve the issue as soon as possible. If we have been unable to resolve your complaint immediately we will:
● Send an acknowledgement of your complaint in writing within 5 working days.
● Confirm who will handle your complaint, and how you can contact them.
In any event we will always aim to resolve your complaint within 15 working days. But if your complaint is particularly complex, or it involves matters which are outside of our direct control, this may be extended and we will keep you informed of the progress we are making as we continue our investigations.
We will provide a final response within eight weeks, including:
● A summary of the complaint
● The outcome of our investigation
● Whether we acknowledge there has been any fault on our side and whether the complaint will be upheld
● Details of any offer to settle the complaint
● If you are an eligible client, a notification of your right to refer the matter to the Financial Ombudsman Service in the unfortunate event that we haven't been able to provide you with a satisfactory resolution within the eight week time period.
Financial Ombudsman Service-
The UK Parliament established the Financial Ombudsman Service as the official independent expert in settling complaints between consumers and businesses providing financial services.
If you have lodged a complaint and are not entirely satisfied with the solution provided by Lighthouse FX, you can contact the Financial Ombudsman Service directly at:
Financial Ombudsman Service
We value your feedback.
If your complaint is in relation to Data Protection, and we are unable to provide you with a final response within one calendar month we will write to you with:
● An explanation as to why we are unable to provide you with a final response and with an indication as to when you will get one.
● If you are an eligible client, a notification of your right to refer the matter to a Data Protection Supervisory authority.
The leading Supervisory Authority is the Information Commissioner’s Office, who can be contacted directly using the following details:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Telephone: +44 (0) 303 123 1113
Copyright © 2018 Lighthouse FX Ltd - All Rights Reserved.
Lighthouse FX Ltd is a company registered in England and Wales (Registration number 11450998). Payment services for Lighthouse FX Limited are provided by FCA regulated strategic partners, the Currency Cloud Limited (Registered in England No. 06323311) and Ebury Partners Limited (registration no. 7088713). For more detailed information please visit the ‘security and regulation’ page.