Privacy Policy / Disclosures

Privacy Policy

General information

Welcome to our Privacy Policy page! For the purposes of this Privacy Statement, Bastion Currency Management Ltd. is the Data Controller. When you use our web site services and other services we may offer, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we it, and what we do with it. When you share information with us, we can make our services even better for you. As you use our services, we want you to be clear how we're using information. This is important; we hope you will take time to read it carefully. We've tried to keep it as simple as possible. We collect, use and disclose your personal information only as permitted under the law. This Privacy Policy may be amended from time to time. The current version will always be available to you on our website, www.bastioncm.com.

Scope & Security

Scope

This policy details how Bastion Currency Management Ltd. (“BCM”, “we”, “our”) collects, uses and discloses your personal information. “Personal information” is defined as any information about an identifiable individual and may be stored in any format. This policy applies to the collection, use and disclosure of personal information of our clients that we deal with in Canada (“you” and “your”). We regularly monitor our security measures and procedures to ensure that they are effective and properly administered. Our Privacy Officer is accountable for overseeing compliance with this Privacy Policy, PIPEDA and any other applicable privacy legislation. We sometimes use outside companies, called third parties, to help us provide the product or service you request. Regardless of the location of these third parties, BCM requires these third parties to meet or exceed the privacy principles in compliance with Canadian privacy legislation.

Security

We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal information you provide to us.

Purpose and Personal information we collect about you

We only collect personal information about you which is necessary to fulfill our contractual obligations with your or your employer and to pursue BCM legitimate business interests.

We may collect the following personal information directly from you, from other financial institutions, from government agencies, from credit bureaus or from references that you have provided to us. The personal identifying information we collect on individuals, either as account holders themselves or those that are authorized signatories or users, including directors and beneficial owners to the businesses that are our clients. Information recorded may include: name, address, telephone number, date of birth and other identifying information to complete a transaction and as required by law or regulation, specifically to be able to offer you the products and services agreed to:

• Professional contact data: This is data that you or your employer may provide to us and includes your name and professional contact details
• Professional profile data: This is data that you may provide to us about your job role, function, business focus
• BCM relationship data: This is data we obtain from our interactions with you, and may include details of the calls you have made to our help desk, visits made to you by our staff, BCM marketing materials you have received, your email communication with our staff, data about your preferred activities for marketing events or the BCM events you have attended
• Credit check data: If you are subscribing to our professional financial and media products whether as an individual or corporation, we may conduct a credit reference check where applicable local law permits us to do so to verify your creditworthiness and identity
• Product usage data: This is data we obtain about your usage of our professional financial and media products and may include when and which products you have used and the content and functionality you have used in those products so that we deliver to you the requested products and services and to process your payments
• System Test data: This is data we obtain about your software, hardware and connectivity environment to enable us to support the products, as well as any non-BCM products you may use
• Publicly available information: This may include data we obtain from directories, websites, public records or media sources
• Referrals: This is data we may obtain about you from other BCM companies or through a BCM website or other BCM clients
• Subscription data: This is data we obtain from our interactions with you and may include the products or data sets to which you subscribe or which you are enabled to access
• Surveys, competitions, prize draws: This is data you may provide when you participate in our competitions, prize draws or surveys
• Compilations of personal information: This is data we may obtain about you from BCM affiliates or third parties and may include conference lists, directories or other lists
• Cookies: Cookies are bits of software that are placed on your computer's hard drive when you visit certain BCM financial and media products. We use cookies to help us identify product features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are using a particular product. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all the product features. In some circumstances you will not be able to use our products if you disable the cookies, as they are integral to the way the product operates
• Internet Traffic Data: If you use our products or services we also gather information about your use of these, such as general types of data accessed, times and volume of use of the services and traffic data. Traffic data includes logs, details of networks, data and systems accessed, details of the sender and recipients of messages sent over our services, times and location of log on or access, duration of sessions, clickstream and similar usage or system data. The above mentioned information about data traffic refers in most cases to an individual user

How We Use Your Information

We may use the personal information you provide us for the purpose of fulfilling our contractual obligations with your or your employer. Specifically, we may use your personal information as follows:

• Administration: We may use the personal information we collect about you to provide our products and services to you and to assist you in your use of our products. This may include setting up your access to a product, providing assistance or training for your use of the product, alerting you to product changes or maintenance periods and invoicing you or your employer for your use of the product

We may also use the personal information you provide us for the purposes of pursuing BCM legitimate business interests. Specifically, we may use your personal information as follows:

• Product/Service development, testing and improvement: We may use the personal information we collect about you to develop, test and improve our products. Where we use your personal information in this way we have a policy of anonymizing the information where possible. We may also ask you to participate in surveys to improve our products and service delivery to you. Our surveys allow for customers to remain anonymous. Personal information obtained in our surveys may also be combined in an aggregate form. We use the data obtained through our surveys to plan and implement developments of, and enhancements to, our products, product ranges and areas of customer service
• Marketing: We may use personal information we collect about you to contact you by email, post, telephone, mobile and SMS with information about BCM, the products you use, BCM products similar to those you use and events that might be of interest to you or your organization. You may ask us to refrain from sending you marketing messages in the "Your Choices" section of this Privacy Statement

In specified countries* if you use our products in the course of your employment, BCM will only send you unsolicited marketing by email if your employer has given its consent for you to receive that marketing, or if your employer has allowed BCM to contact you directly and gain your consent to receive that marketing.

* Germany

Retention, Accuracy and Access of Your Information

Retaining Your Information

BCM will retain personal information as long as is necessary to fulfill the identified purposes, or as required by law. The retention periods for certain information may vary depending on the legal requirements for that information.

When personal information is no longer needed, the information will be destroyed in accordance with the retention periods set out in policy or legislation. We will use care in the disposal, destruction, or de-identification of personal information to prevent unauthorized parties from gaining access to personal information.

Accuracy and Access of Your Information

BCM will make reasonable efforts to ensure that the personal information you provide to us remains as accurate, complete and current as possible for the purpose for which it was collected. In some instances, we ask for your assistance in keeping your information up to date, such as in the case of your address and telephone number. From time to time, we may be required to update your personal information.

Keeping your information accurate and current will help us provide you the best possible service. Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and must provide sufficient detail to identify the personal information and the correction being sought.

BCM will provide you with access to your personal information except where we are prohibited by law from doing so, or are permitted by law to restrict your access and have legitimate reasons for doing so.

Sharing Your Information

We do not sell or otherwise disclose the personal information we collect about you, except as described here.

• Your employer: We may provide your employer with reports containing the product usage data of its employees and details which allow your employer to set up an account so that you can access our products
• For day-to-day operational purposes, as required to process your transactions, manage your account, managing the information technology or to offer you the agreed upon products and services
• Third party providers of content: We may share with our third party content providers such personal information as is necessary for them to confirm that a user is entitled to access their content and to evaluate and manage how that content is used in our services. We do not provide this personal information to our content providers for their marketing purposes
• BCM companies: We may share your personal information with other BCM companies so that they may contact you by e-mail, post or telephone to provide you with information about similar BCM products and events that might be of interest to you or your organization. You may ask us to refrain from sharing your information among BCM companies for their marketing purposes. You may indicate your preference by contacting us as indicated in the "Your Choices" section of this Privacy Statement
• Third Party Service Providers: We may employ third party service providers to process your personal information on our behalf, to the extent it is necessary to fulfill the purposes outlined above. We have contractually bound these service providers to only process data in accordance with our instructions and to comply with specific security and confidentiality requirements
• Disclosure for Legal Purposes: We may provide access to your personal information when legally required to do so including, without limitation, to cooperate with government investigations or other legal proceedings, responding to lawful government requests, investigations or courts
• We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided in a manner that is consistent with this Privacy Statement

Your choices

You may contact us to access the personal information you provide to us and to ask us to update, correct, or delete it from our databases. We offer opt-in for marketing where required by local law. You may also request that we cease using your personal information for marketing purposes. In case of any questions regarding our privacy practices, if you would like to execute your rights or would like to submit a complaint please contact our Data Protection Officer at he email address below.

Disclosures, Terms of Use, High Risk Warning and Advisory Warning

Disclosures, Terms of Use, High Risk Warning and Advisory Warning

General Information: Please read our terms of use carefully before you use our website and/or services. Any user will comply with the terms of use that are set forth by Bastion Currency Management Ltd.

By proceeding to use our website and/or services, you acknowledge your understanding and acceptance of the terms of use, disclosure statement, high risk warning and advisory warning (hereafter referred to collectively as the “terms of use”) and agree to abide to the terms of use set forth in the following. If you do not agree to the terms that are set forth, please cease to use our website and/or services immediately. Bastion Currency Management Ltd. does not provide its services to those that disagree with its terms of use. The information and the views of Bastion Currency Management Ltd. and/or its employees and/or agents and/or affiliates (hereafter referred to collectively as the “employees”) is intended for educational purposes only.

Terms of Use: Bastion Currency Management Ltd. (hereafter referred to collectively as “BCM”) and/or its employees or agents are not registered advisors and do not give investment advice. All comments are an expression of opinion only and to the extent that any communication such as emails, phone conversation, the website (not an exhaustive list) include(s) suggestions as to various possible investment strategies, which users might consider, it does so in only general terms without reference to the personal factors which should determine any user's investment decisions. Nothing contained in this service constitutes personalized investment advice nor should anything be construed in any manner whatsoever as recommendations to buy or sell a stock, ETF, option, derivatives product, futures contract, bond, commodity, foreign exchange or any other financial instrument/product (hereafter collectively referred to as “security” and/or “securities”) at any time. BCM does not warrant the accuracy, completeness or timeliness of the information in this website, and any errors shall not be made the basis for any claim against BCM. While BCM believe their statements to be true, they always depend on the reliability of their own credible sources. Of course BCM recommends that you consult with a qualified investment advisor, one licensed by appropriate regulatory agencies in your legal jurisdiction, before making any investment decisions, and barring that, BCM encourages you confirm the facts on your own before making important investment commitments. This is a financial news and information service and any news, opinions, research, data, or other information contained within this website is provided as general market commentary or information and does not constitute investment or trading advice or form part of any invitation or inducement to buy or sell any security.

Any information that is provided by BCM, cannot be used, posted, copied, or distributed without the permission of BCM, on any other website, blog, bulletin, or third party. The use of the information is strictly for your own personal use and cannot be used in any other manner. If one does choose to use information from BCM and/or its website, in a way that is restricted, the individual can be held legally liable. Additionally, users agree not to use BCM' services and/or website for any unlawful reasons, modify BCM’s services and/or website(s) in any way, mirror the site without prior authorization, harvest or collect information about visitors to the site, or express that the site endorses anything that one does not have prior consent for. You agree to abide by all rules and regulations. BCM can block any user that acts in a questionable way.

Disclosure Statement: Information herein was obtained from sources which BCM believes reliable, but BCM does not guarantee its accuracy. None of the information, advertisements, website links, or any opinions expressed constitutes a solicitation of the purchase or sale of any security. Please note that BCM may already have invested or may from time to time invest in securities that are discussed or otherwise covered in information your receive such as marketing materials and/or BCM's website(s). BCM does not intend to disclose the extent of any current holdings or future transactions with respect to any particular security. You should consider this possibility before investing in any security based upon statements and information contained on the website and/or in any report, post, comment, e-mail, conversation or recommendation you receive from BCM.

High Risk Warning: Foreign exchange and trading in any security or financial market carries a high level of risk that may not be suitable for all clients and/or prospects. Trading with leverage creates additional risk and loss exposure. Before you decide to trade foreign exchange or any security, carefully consider your business objectives, experience level, and risk tolerance. You could lose some or all of capital; do not trade foreign exchange products that you do not understand. Educate yourself on the risks associated with foreign exchange trading and/or trading in any security, and seek advice from an independent financial or tax advisor if you have any questions.

Advisory Warning: BCM may provide references and links to selected blogs and other sources of economic and market information as an educational service to its clients and prospects and does not endorse the opinions or recommendations of the blogs or other sources of information. Clients and prospects are advised to carefully consider the opinions and analysis offered in the blogs or other information sources in the context of the client or prospect’s individual analysis and decision making. None of the blogs or other sources of information is to be considered as constituting a track record. Past performance is no guarantee of future results and BCM specifically advises clients and prospects to carefully review all claims and representations made by banks, foreign exchange brokers, advisors, bloggers, money managers and system vendors before investing any funds or opening an account with any broker or dealer that offers financial instruments for corporate needs, trading or investing. Any news, opinions, research, data, or other information contained within any form of communication (not limited to e-mail, conversations, marketing materials, etc.) is provided as general market commentary and does not constitute investment or trading advice. BCM expressly disclaims any liability for any lost principal or profits without limitation which may arise directly or indirectly from the use of or reliance on such information. As with all such advisory services, past results are never a guarantee of future results.

Disclaimer

FX Evaluation, Transaction Cost Analysis (TCA), In All Probability and/or Transmissions Do Not Create an Advisor-Client Relationship

FX Evaluation: The use and/or submission of Bastion Currency Management Ltd.'s online FX Operations — Risk Management Evaluation (hereafter referred to as "FX Evaluation") and free FX Evaluation Report (hereafter referred to as "Review"), which is subsequently emailed to the user, by a person or Legal Entity (hereafter referred to as "User") does not create an advisor-client relationship. No professional relationship is created by viewing this website, using and/or submitting the FX Evaluation or sending and/or receiving an email. Users do not become clients unless and until Bastion Currency Management Ltd. agrees to act for them and that agreement is confirmed in a retainer agreement or retainer letter in accordance with our usual policies.

Review: Although BCM may comment upon User’s legal documents, investments, financial statements or other documentation in the course of performing the Review, User acknowledges that BCM is not an attorney, investment adviser, investment intermediary, tax professional or an accountant nor is BCM providing legal, investment, tax, auditing or accounting services or opining on representations made in any financial statements. User further acknowledges that User should consult with its own legal, investment, tax, auditing and accounting advisors regarding any matters requiring legal, investment, tax, auditing or accounting advice. User maintains control of all decisions and should reject advice or opinions that they do not agree with.

In All Probability: The receipt and/or use of Bastion Currency Management Ltd.'s In All Probability weekly report (hereafter referred to as "FX Product"), which is subsequently emailed to the user but can also be view on our website via a web broswer, by a person or Legal Entity (hereafter referred to as "User") does not create an advisor-client relationship. No professional relationship is created by viewing this website, receiving and/or using the FX Product or sending and/or receiving an email. Users do not become clients unless and until Bastion Currency Management Ltd. agrees to act for them and that agreement is confirmed in a retainer agreement or retainer letter in accordance with our usual policies.

Transmissions Are Not Confidential: Bastion Currency Management Ltd. does not guarantee the confidentiality of the content of any transmission (e.g., email, form submission‐not an exhaustive list) facilitated by this website. If you wish to provide confidential information to any of the employees at Bastion Currency Management, please contact the employee by telephone.