Privacy Policy

Effective December 1st, 2016

 

Personal Information We Collect
Sources of Personal Information
How We Use Personal Information
Disclosure of Personal Information
How We Protect Personal Information
Personal Information and Our Website
Data Privacy for European Union Residents
Contact Compliance

 

Commonwealth Foreign Exchange, Inc. (“Commonwealth”) is devoted to safeguarding our customers’ private information and ensuring the highest level of confidentiality of customer records. This Privacy Policy describes the kind of information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information. Commonwealth, its personnel, and its affiliates shall strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information.

Financial institutions choose how they share your personal information. Federal laws require financial companies to handle information about consumers securely and give consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, use, share, and protect your personal information. Please read this Policy carefully to understand how we manage customer data.

We collect, retain and utilize information about you:

  • To operate our business and make products, services and other opportunities available;
  • To create and verify your account and update and maintain your account profile; and
  • To be in compliance with legal and regulatory requirements.

What Personal Information We Collect

We collect only the necessary personal information to enable us operate our business; to make products, services and other opportunities available to you; and to be in compliance with this Policy and with legal and regulatory requirements.  We are the sole owners of the information collected on our website, through account usage, and through our business relationships with our customers.

If you choose to become a customer, we will request certain information about you, including personal information such as: your name, mailing and/or email address, bank information, Driver’s License, passport and/or other photographic identification, without which we cannot open your account. We may also obtain information from your transactions with us and other information for payment purposes, to provide our products and services, or to comply with legal requirements.

Federal law requires us to obtain, verify and record your personal information – such as your name, address and date of birth – in order to confirm your identity. We may share this information with our service providers in order to evaluate whether to maintain your account. The information provided by you and the results of the verification process will be retained by Commonwealth and/or our service providers, for the amount of time required by law, for audit and fraud prevention purposes.

Sources of Personal Information

Some of the information we collect is of a personal nonpublic nature. “Personal nonpublic information” means all personal information on applications to obtain financial services (account applications), account histories (transaction history) and the fact that an individual is or was a customer.

We collect this information from the following sources:

  • Personal information provided to us in an Account application, such as your name, address, Social Security number, birth date, bank information, assets, and income;
  • Personal information we obtain while verifying your identity, including credit reports and public records;
  • Personal information resulting from Orders you submit, such as confirmations and ACH authorizations; and
  • Information derived from navigation and usage of our website and online platform

How We Use Personal Information

We utilize your personal nonpublic information to:

  • Comply with applicable laws and regulations, most notably anti-money laundering and counter-terrorism financing legislation;
  • Conduct our business;
  • Create and verify new account profiles;
  • Develop and maintain existing account profiles;
  • Maintain customer accounts and carry out customer-related requests;
  • Conduct internal risk assessments and audits;
  • Design new products/services or improve existing products/services;
  • Understand your financial needs so that we can provide you with quality products and superior service; and
  • Protect against fraud.

While some personal information may be collected over the telephone, if we ever record or monitor telephone calls, it is for use as evidence of business transactions, to ensure quality control and to improve internal training measures.

Disclosure of Personal Information

We do not share nonpublic personal information about our customers (present, former and potential) with anyone, except as required by law, or as follows:

  • To any person when you authorize such disclosure;
  • To computer services consultants and technicians or other security consultants, in order to ensure the confidentiality and security of customer records;
  • To financial service providers or consultants to carry out requested services, and/or to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability;
  • To independent auditors or consultants in order to carry out institutional risk control;
  • To government or regulatory agencies, including self-regulatory organizations and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation;
  • To customer due diligence and investigations vendors;
  • To swap data repositories; and
  • To comply with any other laws or regulations.

All companies that act on our behalf are contractually obligated to keep information that we provide to them confidential, and use the information only to provide services we have asked them to perform for you and us.

We do not sell our customer information to anyone or any company. We do not share your information with non-affiliated third parties for their independent use. We may report the credit history of your transactions with us to the appropriate credit reporting agencies.

We do not disclose any nonpublic information about our customers or former customers to anyone other than in connection with the administration, processing and servicing of customer accounts as described above or to our accountants, attorneys and auditors or as otherwise permitted or required by law.

How We Protect Personal Information

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities.

We have developed precautions that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers.

Commonwealth maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information. We will continue to test and update our technology to improve the protection of your information.

We protect your nonpublic personal information by:

  • Restricting access to customer information to only those personnel for whom the information is necessary;
  • Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures;
  • Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations; and
  • Conducting an Information Security Training and Awareness training program to communicate and educate employees about information security policies and procedures in order to make them aware of their roles and responsibilities in safeguarding information resources.

Personal Information and Our Website

Commonwealth uses firewall barriers and digital certifications to maintain the security of your online session and information. We will not collect any non-public personal information about visitors to our website, unless information is provided it to us voluntarily or derived from website navigation and usage of the Commonwealth website and online platforms. Please note that by providing Commonwealth with non-public personal information, a customer or potential customer consents for us to use the data to conduct our business, to make available products and services that may be of interest to our customers and for the development of web statistics.

We may gather and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. Commonwealth uses cookies and similar technologies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. If you do not want to allow our website to place a cookie on your computer, you can change your browser’s settings to deny cookies; however, this may affect your experience with certain features of our website. Our websites do not respond differently when accessed by a browser that uses a do not track signal or similar mechanism.

We have established procedures to keep your information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner. If you believe our customer records contain incorrect information about you, call us at 1-800-239-2389 or send an email to compliance@commonwealthfx.com.

Data Privacy For European Union Residents

The EU Data Protection Directive

The European Commission’s Directive on Data Protection (“Data Protection Directive”) went into effect in October 1998, and would prohibit the transfer of personal data to non-European Union countries that do not meet the European Union (“EU”) “adequacy” standard for privacy protection. The Data Protection Directive imposes regulatory requirements with respect to your personal nonpublic information. The U.S.-EU Safe Harbor Framework, which was approved by the EU in 2000, provides non-EU businesses with guidance on how to demonstrate adequate privacy protection, as defined by the Directive.

Commonwealth complies with the seven Safe Harbor Privacy Principles in the following ways:

  • This Privacy Policy communicates to our customers, potential customers, and visitors to our website that information is being collected, what information we collect, and how;
  • We collect information for only the purposes stated above and for no other purposes;
  • We will not transfer your sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying your sexual preferences) to any third parties unless you expressly opt-in. We will only disclose or share your non-sensitive personal information with third parties with whom we have written agreements in place requiring the same level of privacy protection as required by these Principles;
  • Once collected, personal information is maintained in a safe and secure location to protect against potential abuse, theft, or loss;
  • Only trained Commonwealth personnel collect your personal data;
  • You are always free to access your personal data and you can correct any inaccuracies at any time or update your information by sending an email to compliance@commonwealthfx.com; and
  • We are accountable for adhering to all seven of these principles and want to hear from you if you feel we have not done so. If you have suggested areas of improvement or wish to file a complaint, please submit a customer complaint form.

Purpose: We collect data only for the purposes stated above and for no other purposes.

Notice: Our Privacy Policy informs our customers, potential customers, and visitors to our website that we collect personal information, what information we collect, and how; how you can contact Commonwealth with any inquiries or complaints; the types of third parties to which we disclose the information; and the ways in which we limit the use and disclosure of the information. From time to time, we may make changes to the Privacy Policy. We will notify our customers of material changes by posting a revised Privacy Policy at www.commonwealthfx.com. We recommend that you regularly check the site to review the most current Privacy Policy.

Consent: You have the opportunity to opt out from having your personal information disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized. We will not share your sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying your sexual preferences) with a third party unless you consent to the transfer by opting-in.

Security: If you consent to allow us to collect personal data, we pledge to keep it safe and secure from potential abuse, theft, or loss. We are committed to taking all reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Disclosure: We work with several companies to help us deliver our services to you. In some cases, these companies will have access to some of your personal information to enable us to provide services to you. They are not permitted to use your information for their own purposes. We will only transfer information to affiliated third parties with whom we have a written non-disclosure agreement in place requiring that the third party provide at least the same level of privacy protection as is required by these principles.

Access: You are always free to access your personal data and to correct any inaccuracies, amend, or delete information at any time by sending an email to compliance@commonwealthfx.com. We will use reasonable efforts to allow users to update/correct personal information previously submitted which the user states is erroneous to the extent that such activities will not compromise privacy or security interests. Also, upon a user’s request, Commonwealth will use commercially reasonable efforts to functionally delete the user and his or her personal information from its database;

Accountability: We are accountable for adhering to all seven of these principles and appreciate your feedback if you feel we have not done so. If you have suggestions for areas of improvement or wish to submit a complaint, please submit a customer complaint form. All individual complaints and disputes will be investigated and resolved and damages awarded where the applicable law or private sector initiatives so provide; we conduct internal testing to ensure that we are complying with the Safe Harbor Privacy Principles; and we take remedial actions to quickly address failures to comply with the principles.

Further guidance on the Safe Harbor Privacy Principles is made available by the Department of Commerce’s frequently asked questions and answers.

CONTACT US

If you have any questions about this Privacy Policy or our data security practices, please contact us at: compliance@commonwealthfx.com.

If you believe our customer records contain incorrect information about you, call us at 1-800-239-2389 or email us at compliance@commonwealthfx.com.

Commonwealth may, at its sole discretion, change modify, add, or delete portions of the Privacy Policy. We will notify our customers of material changes by posting a revised Privacy Policy at www.commonwealthfx.com. We recommend that you check the website on a periodic basis to review the most current Privacy Policy.

This Privacy Policy does not extend to third party sites that may be linked to our website.