Privacy policy

Respecting Your Privacy

We value the confidentiality of your information and the privacy of individuals. This Privacy Policy outlines how Tag Fx (“Tag Fx”) manages, handles, and protects the personal information and data it holds about you. This includes information and data that Tag Fx collects during the provision of its products and services to you and the information and data that Tag Fx retains after the relationship has ended. This Privacy Policy also applies to information and data that Tag Markets collects from third parties, including information and data received through credit reporting bodies or agencies.

This Privacy Policy details how you can access and control the information Tag Fx holds about you, request corrections to your information, and make a complaint if you have concerns about how Tag Fx has handled your information.

References to ‘us,’ ‘our,’ ‘we,’ or ‘it’ in this Privacy Policy refer to Tag Fx, as required by the context unless stated otherwise. Similarly, references to ‘you,’ ‘your,’ ‘yours,’ or ‘yourself’ in this Privacy Policy refer to Tag Fx’ customers, potential customers, shareholders, and others, as the context requires unless stated otherwise.

This Privacy Policy will be reviewed periodically to take into account new laws and technology, changes in the operations and practices of Tag Fx, and to ensure it remains appropriate to the changing environment. Any information we hold will be governed by the most current Privacy Policy displayed on our corporate website(s). Additionally, over the course of our relationship with you, we may provide you with further details on how we handle your information. This could be when you complete an application or form or receive important disclosure documents from us, such as terms and conditions. You should also review these statements as they may contain more specific details.

Collecting Your Personal Information

We collect personal information and data about you to perform various functions and activities effectively. If we do not collect your personal information, we may not be able to interact with you or provide you with a product or service. Due to the nature of the products and services we provide and our associated regulatory obligations, we do not offer the option of allowing you to deal with us on an ‘anonymous’ basis. We also collect your personal information if required by law.

We obtain most of the information directly from you through our application or other forms, and from maintaining records of information provided in the course of ongoing customer service. For example, you will need to provide us with your information when you open a trading account, fill in an application form, deal with us over the phone, send us a letter, or use our website(s).

When you apply for one of Tag Fx’ products or services, we may collect and hold personal information from you, including (but not limited to) your name, address, telephone number, email address, tax file number (TFN), date of birth, annual income, other financial details, employment details, credit history, and your transaction history.

Collecting Information From Third Parties

There may be occasions when we collect personal information about you from a third party. We may collect personal information about you that is publicly available, including information from telephone directories, the electoral roll, or other relevant websites. For example, we may collect personal information about you from:

• Credit reporting bodies and/or other credit providers – to collect information about the products they provide to you and your credit history;
• Organizations we have an arrangement with to jointly offer products;
• Marketing companies – to collect information about you so we can provide you with a product or service that may be of interest to you; and
• Brokers and/or other related entities who may have introduced you to us.

We may also collect information and data about how you use our website and/or other websites to help us better tailor our services to you. For example, we may automatically do this when you click on a link from our website or visit an external website that displays a Tag Fx’ advertisement, or when you log onto our online portal or service (for more information, see the section ‘Use of Cookies and other Tracking Technology’). Any disclosure and/or processing of this information will be in accordance with this Privacy Policy.

Collecting Sensitive Information

In this Privacy Policy, ‘Sensitive Information’ refers to personal information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information, or health information.

We WILL NOT collect, use, or disclose sensitive information about you unless we need the information for one of our functions or activities (or when we are legally required to do so) and we have already obtained your consent.

If you provide us with personal information that we have not requested, we will only retain the information that we are otherwise entitled to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain, then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

Using Your Personal Information

We may use personal information we collect about you where there is a legal basis to do so, where that information is necessary to carry out obligations arising from agreements between you and Tag Fx, or where it is within our legitimate interest to do so.

• We may use your personal information for several purposes, including:
• To consider your request for a product or service;
• To enable us to provide a product or service;
• To tell you about other products and services that may be of interest to you;
• To assist in arrangements with other organizations in relation to a promotion or provision of a product or service;
• To manage accounts or perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring, and staff training, collecting debts, and market or customer satisfaction research);
• To consider any concerns or complaints you raise against Tag Fx and/or to manage any legal action between you and Tag Fx;
• To prevent or investigate any actual or suspected fraud, unlawful activity, or misconduct;
• To identify you or establish your tax status under any foreign legislation, regulation, or treaty pursuant to an agreement with any tax authority; and
• As required by relevant laws, regulations, codes of practice, and external payment systems.

As part of our service to you, we may use personal information we have collected about you to let you know about products and services or promotions and other opportunities in which you may be interested. We may contact you from time to time to let you know about new or existing products or services. We may also disclose your personal information to related entities or business partners to enable them to tell you about a product or service. Depending on the situation, and where these activities do not arise from our legitimate interests, your consent to our activities will be required.

You may contact Tag Fx at any time if you do not wish to receive such communications. Please note that we do not use any information we have received about you through the credit reporting system for marketing purposes.

Sharing Your Personal Information

Depending on the product or service concerned and particular restrictions on sensitive information, when it is necessary, we may need to share or disclose personal information about you to the following organizations:

• Any related entities of Tag Fx in the world which provide financial and other services for Tag Markets;
• Service providers and specialist advisers who we have contracted to provide Tag Fx with administrative, financial, taxation, insurance, research, or other services;
• Credit reporting or reference agencies;
• If you were introduced to Tag Fx by a third party, we may disclose personal and account information about you to them, their related companies, and licensees or authorized representatives;
• Credit providers, courts, tribunals, and regulatory authorities as agreed or authorized by law; and
• Anyone authorized by an individual, as specified by that individual or the contract.

If there is disclosure of your personal information to an organization not listed above, we will first obtain your free and informed consent. In some circumstances, the nature of the product or service you request may require us to disclose your information overseas, and the countries to which we may disclose your information will depend on your particular circumstances. When we disclose your information (including cross-border disclosures), we are required to take measures to ensure your information is treated in accordance with the standards that apply in Vanuatu, and where applicable, with data regulation legislation. The foregoing standards apply to our disclosure of your personal information, unless, in rare cases, we have legally obtained your free and informed consent not to take these measures or are otherwise not required to do so.

Obtaining Your Consent

We may require your consent to use and/or disclose personal information about you in particular ways. For example, we need your further consent if we need to use your information for a purpose that is not related to the purpose for which we collected your information in the first place.

Depending on your circumstances, the consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to your product terms and conditions which contain information about the use or disclosure).

Use of Cookies and Other Tracking Technology

Our website(s) have links to external third-party websites that may benefit you. Please keep in mind that these third-party websites are not covered by this Privacy Policy and these sites are not subject to our privacy standards and procedures.

We also use cookies to give you access to certain pages of our website(s) without having to log in each time you visit. Likewise, we may use independent external service providers to track the traffic and usage on our website(s). Please note that ‘cookies’ are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on our website(s), what you’ve downloaded, where you came

from, and to ensure your information is secure. The purpose of cookies is to provide you with a more relevant and effective experience on our website(s), including presenting web pages according to your needs or preferences.

Cookies are frequently used on many websites on the internet, and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. Please note, however, that you may not be able to access some parts of our website(s) if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website(s). We, therefore, recommend you have the cookies enabled to benefit from all the services on the website(s).

Please also note that we are constantly improving the functionality on our website(s). This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this Privacy Policy as it may be updated from time to time.

Managing Your Personal Information

Tag Fx takes all reasonable precautions to protect your personal information and data from misuse and loss, and from unauthorized access, modification, and disclosure by ensuring that your personal information can only be accessed by people properly authorized to have access.

We train staff who handle your personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of customer privacy very seriously and will impose appropriate penalties, including dismissal.

Your personal information is stored in a combination of secure computer storage facilities and paper-based files and other records, and irrespective of the format of the information, we take steps to protect the personal information we hold from interference, misuse, loss, unauthorized access, modification, or disclosure. We maintain physical security, such as locks and security systems, over our paper and electronic data stores and premises. We also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems. We continually maintain and monitor our online security systems to ensure that our online services are secure and that your personal information is appropriately protected when you use these services.

Your personal information may also be processed by us and/or our third-party service providers (including storage and transfer) outside of Vanuatu.

Protecting Your Privacy

You can help Tag Fx to protect your privacy by staying informed about our security requirements and contacting us immediately if your contact details change.

We also require you to keep your personal customer information such as passwords and user details confidential and secure at all times. This means that you should not disclose your personal user information to any other person. You should contact Tag Fx immediately if you believe that your personal user information may have been disclosed to another person or if you would like to change your password or user details.

Accessing Your Personal Information

You have the right to find out what personal information we hold about you, including what information we have obtained through the credit reporting system. You should contact Tag Fx if you wish to find out about the personal information we hold about you (please note that your request should be made in writing for security reasons, and we may need to verify your identity before giving you access). We are generally able to deal with your request immediately. However, if the request is complex, then such a request will be dealt with within 14 to 30 business days. Further, depending on the complexity of your request, we may need to charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing, and copying any material requested. If the information sought is extensive, we will advise and disclose the likely cost in advance and can help to refine your request if required.

Correcting Your Personal Information

If you believe that the personal information Tag Fx holds about you is inaccurate, incomplete, or out-of-date as a result of changes of address and other personal circumstances, you should contact us as soon as possible. We will promptly update any personal information that is inaccurate, incomplete, or out-of-date. We can update your personal information over the telephone or by email from your registered email address (please note that we will need to confirm your identity before making any amendments).

Expressing Your Privacy Concern

If you consider or believe that any of our actions breach this Privacy Policy or otherwise don’t respect your privacy, you can contact our Support team using the following methods:

Email: [email protected]