Privacy Policy
Personal information (possibly including sensitive data) within the meaning of the Processing of Personal Data (protection of individuals) Law 138 (1), as amended in 2003 by Section 37 (1) 2003 provided by Client to AFX by opening the Account, placing Orders and entering into Contracts may be processed by AFX for the purposes of performing its obligations under this Agreement, administering the relationship with the Client and analysing, improving and developing the trade products and services of AFX. The above data may be disclosed to service providers and other suppliers (within the European Economic Area or otherwise including countries which do not offer “adequate protection” within the meaning of the EU Directives on data protection) for any purpose relating to the operation of the Account including, but not limited to, processing of instructions, generation of confirmations, operation of control systems and management of information systems, allowing staff of service providers and other suppliers who share the responsibility for managing the relationship between AFX and the Client to view such data. AFX may also disclose the above data to the Client’s introducing broker or agent, if any, as necessary to enable them to administer the relationship with the Client or to take any action in connection therewith.
Unless the Client requires AFX not to do so, personal information may also be used by AFX (and shared with the parties indicated above, as necessary) for marketing to the Client AFX products and services, as well as those of third parties which AFX believes may be of interest to the Client.
AFX has security procedures covering the storage and disclosure of the Client’s personal information to prevent unauthorized access and to comply with legal obligations. Before transferring personal data to service providers, other suppliers or parties for processing or other purposes, AFX shall ensure that adequate contractual arrangements complying with applicable legal standards are in place to protect the confidentiality of the information.
The Client may require AFX to provide details of the personal information held about the Client, the purposes for which the information is processed and the persons or class of persons to whom the information is disclosed. AFX may charge a fee to provide these details, the amount of which is available upon request. The Client may also require AFX to correct, delete and/or block personal information from further processing if that information is inaccurate.
Subject to the foregoing, neither party may disclose to any person any information relating to the business, investments, finances or other matters of a confidential nature of the other party of which it may become possessed in connection with this Agreement and its performance by the other party, and each party shall use all reasonable endeavours to prevent such disclosure. Notwithstanding the above, each party (the “Disclosing Party”) may disclose information about the other party, this Agreement, the Account and any trade thereon as the Disclosing Party may be required by any law, rule or regulatory, law enforcement or tax authority or as the Disclosing Party reasonably believes to be necessary to properly perform its obligations under this Agreement or to exercise and enforce its rights thereunder (including, without limitation, as set forth in Section 16.4) without prior notice to the other party.


