Privacy and Cookie Policy

Exchange4free Privacy and Cookies Policy

The Exchange4free service is provided by Exchange4free Limited (“E4F”). E4F are committed to safeguarding the privacy of our customers and website users. Any personal information you provide to us will be dealt with in accordance with the following privacy principles.

This Privacy Policy should be read in conjunction with the client agreement that you enter into with E4F ("Client Agreement").

Our aim is to give you peace of mind that any personal information will be used fairly and to provide transparency over how we use personal data.

We suggest that you review this Privacy Policy before registering for an account with Exchange4free. Client confidentiality is our main concern and through good practices we strive to ensure that:

  • we will only collect information which is necessary for adherence to the regulations and/or helps us to improve our service;
  • any personal information is collected fairly; and
  • all personal information is stored securely.
  • we will only use your information as set out in this Privacy Policy.
If you have any further questions about how Exchange4free handles your information please don’t hesitate to get in touch.

How do we collect information about you?

Like many financial services organisations, Exchange4free collects information about you when you visit our website, register for an account or when you contact us over the phone or in writing.
When you register for an account with us we collect, process and store information such as your name, postal address, email address, telephone numbers, date of birth, etc. Once your account is fully set up and you begin to transact with us we will collect, process and store financial and transactional information.

Our website makes use of cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

Why do we collect your information?

We use your personal information to allow us to process your registration, process any transactions you may book through us and to maintain the accuracy of information on your account, as required by regulation and industry standards.

Registration and Administration

We use your information to enable you to register with us. Once you have an account with us we will use your details to contact you and to reply to any queries or requests. We may also use your information to contact you and update your account details.

Our Products and Services

We use your information in order to supply our products and services and to meet our contractual obligations to you. We may also notify you of any changes relating to our products and services that may affect you.

Prevention and Detection of Crime

The law requires us to undertake due diligence on our customers to help prevent money laundering and other types of financial crime. To do this, we use electronic verification tools however, where electronic verification is not possible, we will require physical documentation.

We may need to pass your information on to Governmental departments, regulatory bodies, the police/law enforcement agencies or to a court of law. This would only be done for lawful purposes or, for example, to assist in the prevention of a crime.

Marketing

We may use your information to keep you up to date concerning our products and services.

We may send you emails inviting you to participate in surveys or asking for feedback on our services so that we can keep improving them. We may share the survey results with some of our affiliated third parties, but only the aggregate results. You cannot be identified by the results we share with these third parties.

We may market our services to you through social media platforms using information you provide to us when you interact on our website or sign up for our services which means we may pass your information onto third parties, such as Facebook, for this purpose. Please contact us if you do not want to be part of these sorts of adverts by emailing This email address is being protected from spambots. You need JavaScript enabled to view it.

Monitoring

We record all our telephone calls for security and training purposes.

1. What Information do we Collect?

We will collect your Personal Information only for the purpose of providing our services to you and any purpose that is directly incidental to the provision of those services and the improvement thereof.

We may collect, store and use the following kinds of personal information:

  • a. Information that you provide to us for the purpose of registering with us.
  • b. Information relating to any transactions carried out between you and us on or in relation to our website.
  • c. information about your computer and about your visits to and use of this website
  • (Including your IP address, geographical location, browser type and version, operating system, referral source, length of visit and page views)
  • d. Information that you provide to us for the purpose of subscribing to our website services, email notifications and newsletters.
  • e. Any other information that you choose to send to us
  • We will seek your consent to the use of your Personal Information expressly by you reading this document and you choosing to tick the box on the exchange4free registration process that you agree to this policy.

    Your consent may also be given by an authorised representative or a person having Power of Attorney.

    You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.

    We may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.

    2. Disclosure of Personal Information

    We may disclose your personal information to any of our employees of officers insofar as reasonably necessary for the purposes set out in this privacy policy.

    There may be circumstances in which we are obliged to collect, use, or disclose certain Personal Information without your consent. Such circumstances could include the following:

    • a) A serious and imminent threat to someone's life, health or safety;
    • b) A serious threat to public health or public safety;
    • c) Unlawful activity has been, is being or may be engaged in;
    • d) Disclosure is required or authorised by law;
    • e) Prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law including the enforcement of laws relating to the confiscation of the proceeds of crime; or
    • f) The use or disclosure is necessary for the protection of the public revenue, the
    • g) Prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

    Except as provided in this privacy policy, we will not provide your information to third parties.

    3. Limiting Collection and Retention of Information

    The amount and type of information collected by us will be limited to that which is necessary to provide our services and the information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected.

    You acknowledge that we are obliged under the relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 5 years after your last transaction with us.

    Subject to any legislative requirements, we will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.

    4. Accuracy of Information Held

    We will make reasonable efforts to ensure that your Personal Information is sufficiently accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.

    We will not routinely update your Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.

    5. Cookies

    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. E4F makes use of cookies to help personalise your web experience, ensure you can navigate our website efficiently and perform certain functions. Due to their core role of enhancing or enabling usability or site processes, disabling cookies may prevent you from using certain parts of this website. It will also mean that some features on this website will not function if you do not allow cookies.

    We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http://www.google.com/privacypolicy.html.

    For more information about cookies, please go to http://www.aboutcookies.org/

    6. Using your Personal Information

    Personal information submitted to us via this website will be used for the purposes specified in this privacy policy or in relevant parts of the website.

    We may use your personal information to:

    a) Administer the website

    b) Improve your browsing experience by personalising the website;

    c) Enable your use of the services available on the website;

    d) Send you general (non-marketing) commercial communications

    e) Send you email notifications which you have specifically requested

    f) Send you marketing communications relating to our business which we think may be of interest to you, by email or similar technology (and you can inform us at any time if you no longer require marketing communications)

    g) Deal with enquiries and complaints made by or about you relating to the website;

    h) Keep the website secure and prevent fraud;

    i) Verify compliance with the terms and conditions governing the use of the website

    7. Security

    We have in place a range of security safeguards to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held.

    The methods of protection we employ may depend on the sensitivity of the information and the format in which it is contained. Security measures include: technological measures including SSL 128 bit encryption for all data transfers over the Internet, physical measures such as locked filing cabinets and restricted access to offices and strategic measures such as security clearances and limiting access to a "need-to-know" basis.

    We make every effort to ensure that our staff are aware of the importance of maintaining the confidentiality of personal information, however you acknowledge that authorised employees, agents, representatives and third parties may require access to your Personal Information in order to enable us to provide our service and we cannot accept responsibility for any unauthorised activities on their part.

    You acknowledge that no data transmission over the internet or the telephone can be guaranteed to be perfectly secure. Any Personal Information you submit to us or access electronically or over the telephone is done at your own risk. We do not guarantee or warrant the security of information transmitted in these ways. You acknowledge that third parties could unlawfully intercept your transmissions or may wrongly instruct you to disclose Personal Information while posing as E4F’s representatives.

    8. External Websites

    Our website may be linked to or from third party websites. These links are provided as a convenience only. We are not responsible for the content or privacy principles of websites that are linked to or from our website. You are advised to review the privacy policies of any third-party websites you visit.

    9. Access

    You have the right to request details of the information we hold about you, a description of that data, the purposes for which it is being used and any parties with which we share your information.
    We may charge you an administration fee for providing this information. Your request should be made in writing to This email address is being protected from spambots. You need JavaScript enabled to view it.

    We will upon request and within one (1) month of any such request allow you access to your Personal Information. The requested information shall be provided or made available in a form that is generally understandable.

    If you point out to us that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.

    You acknowledge that there may be circumstances in which we may refuse access to some or all of your Personal Information, including where the provision of access would be too costly, the information may contain references to other individuals or for legal, investigative, security or commercial proprietary reasons.

    10. Policy Amendments

    We may update this privacy policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

    11. Complaints

    We have procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Information. For more information, see our Complaints Policy.

    We take all complaints seriously and will investigate all complaints.

    12. Contact

    If you have any queries about this Privacy Policy or any complaints about our privacy practices, please contact our Compliance Officer at This email address is being protected from spambots. You need JavaScript enabled to view it.

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