Privacy policy

1. Introduction

FIFO Markets (“FIFO Markets”, “we”, “us” or “our”) is committed to protecting the privacy, confidentiality and security of the personal information of our clients, prospective clients, website visitors and users of our digital services.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, register for an account, access our client portal, use our mobile application, open a trading account or communicate with our customer support team.

By using our services, you acknowledge that you have read this Privacy Policy. Where applicable law requires consent, we will obtain it separately or through an appropriate consent mechanism.

2. Company Information

Company Name: FIFO Markets Financial Ltd

Brand Name: FIFO Markets

Client Portal: https://client.fifomarkets.com/login

Privacy Contact: support@fifomarkets.com

Registered office, company registration details, regulatory information and the applicable data protection contact details should be inserted before publication.

3. Scope of This Policy

This Privacy Policy applies to information collected through:

• The FIFO Markets website and client portal.

• FIFO Markets mobile applications.

• Trading account registration and account management.

• Know Your Customer (KYC) and verification procedures.

• Deposits, withdrawals and payment processing.

• Customer support, email, telephone and other communications.

• Introducing Broker (IB), partnership and referral programmes.

• Marketing communications and website analytics.

This Policy should be read together with our Client Agreement, AML/KYC Policy, Deposit and Withdrawal Policy, Cookie Policy and other applicable legal documents.

4. Personal Information We Collect

Depending on the services you use, we may collect the following categories of information.

4.1 Identification Information

• Full legal name.

• Date of birth.

• Nationality and country of residence.

• Residential address.

• Email address and telephone number.

• Government-issued identification documents.

• Passport, Emirates ID or other applicable identification details.

• Proof of residential address.

• Photographs, selfies or verification images where required.

4.2 Account and Trading Information

• Client account number and login details.

• Trading platform account identifiers.

• Account type, leverage and trading preferences.

• Order history, open positions and transaction records.

• Deposits, withdrawals, balances and account statements.

• Margin, equity and other trading-related information.

• Account access records and relevant system logs.

4.3 Financial and Payment Information

We may collect information necessary to process and verify payments, including:

• Bank account holder name and bank details.

• Payment method and transaction reference.

• Deposit and withdrawal amounts.

• Payment provider transaction identifiers.

• Cryptocurrency wallet addresses and relevant blockchain transaction details.

• Source-of-funds and source-of-wealth information where required.

• Information needed to investigate suspicious or disputed transactions.

Where payment services are provided by third parties, those providers may independently collect and process payment information under their own privacy policies.

FIFO Markets does not intend to collect or store clients' complete payment card security codes or unnecessary payment credentials.

4.4 KYC, AML and Compliance Information

To meet applicable legal, regulatory and internal compliance requirements, we may collect:

• Identity verification results.

• Sanctions and politically exposed person (PEP) screening results.

• Adverse media screening results.

• Source-of-funds and source-of-wealth documents.

• Information relating to suspicious transactions.

• Relevant compliance correspondence and investigation records.

• Additional documentation required to establish eligibility for our services.

4.5 Technical and Device Information

When you use our website, portal or application, we may collect:

• IP address.

• Device type and operating system.

• Browser and application version.

• Login timestamps and session information.

• Approximate location derived from technical information.

• Website pages viewed and interactions.

• Error reports, diagnostic information and security logs.

We use this information for service operation, troubleshooting, security and fraud prevention.

4.6 Communications and Marketing Information

We may retain records of emails, support tickets, telephone communications, complaints and other correspondence.

Where permitted by law, we may also collect your communication preferences, marketing consent and interactions with our promotional materials.

5. How We Collect Personal Information

We may collect information:

• Directly from you when you register, submit documents or contact us.

• Through our client portal, website or mobile application.

• From trading platforms and technology providers supporting your account.

• From payment service providers and financial institutions involved in transactions.

• From identity verification, sanctions screening and fraud prevention providers.

• From publicly available sources where permitted by law.

• From introducing brokers, authorised representatives or other parties where lawful and appropriate.

• Through cookies and similar technologies, subject to applicable requirements.

Where information is obtained from a third party, we will handle it in accordance with applicable privacy and data protection laws.

6. Purposes for Processing Personal Information

FIFO Markets may process personal information for the following purposes:

6.1 Account Registration and Administration

• Create and maintain client accounts.

• Verify identity and contact details.

• Assess account eligibility.

• Provide access to the client portal and trading services.

• Manage account settings and client requests.

6.2 Trading Services

• Facilitate access to trading platforms.

• Maintain trading and transaction records.

• Provide account statements and trading reports.

• Investigate trading disputes and technical issues.

• Communicate information relating to account activity.

6.3 Deposits and Withdrawals

• Verify payment ownership and transaction details.

• Process eligible deposits and withdrawal requests.

• Reconcile payments and account balances.

• Investigate failed, delayed or disputed transactions.

• Detect and prevent payment fraud.

6.4 Legal and Regulatory Compliance

• Perform KYC and AML checks.

• Conduct sanctions screening.

• Meet applicable reporting and recordkeeping obligations.

• Respond to lawful requests from competent authorities.

• Prevent money laundering, terrorist financing, fraud and other unlawful activities.

6.5 Security and Fraud Prevention

• Protect accounts from unauthorised access.

• Monitor unusual login and transaction activity.

• Investigate suspected misuse of our systems.

• Maintain the integrity and availability of our services.

6.6 Customer Support and Service Improvement

• Respond to enquiries and complaints.

• Resolve technical and account-related issues.

• Improve the reliability and usability of our services.

• Maintain internal quality and operational records.

6.7 Marketing and Business Communications

Where permitted by law and subject to applicable consent requirements, we may send service announcements, product updates, educational materials and promotional communications.

You may opt out of promotional communications at any time. Essential account, security, transaction and compliance messages may continue to be sent when necessary.

7. Legal Basis for Processing

Depending on the applicable jurisdiction and circumstances, we may process personal information on one or more of the following grounds:

• Contract: Processing necessary to establish or perform our agreement with you.

• Legal obligation: Processing required to comply with applicable laws and regulations.

• Consent: Processing based on your valid consent where required.

• Legitimate interests: Processing necessary for appropriate business interests, provided those interests do not override your applicable rights.

• Legal claims and public interest: Processing necessary for establishing, exercising or defending legal claims, or for another lawful purpose recognised by applicable legislation.

Where processing is based on consent, you may withdraw that consent, subject to legal limitations and the consequences of withdrawal.

8. Sharing of Personal Information

We do not sell personal information to third parties as a commercial data-broker activity.

We may share relevant information with the following categories of recipients when necessary and lawful:

8.1 Technology and Trading Providers

Trading platform providers, CRM providers, bridge providers, hosting companies, cybersecurity providers and technical support teams may process information necessary to operate our services.

8.2 Banks and Payment Providers

Banks, payment processors, cryptocurrency payment providers and other authorised payment service providers may receive transaction and verification information required to process payments and prevent fraud.

8.3 Identity Verification and Compliance Providers

KYC, AML, sanctions screening and fraud prevention providers may receive information necessary to perform verification and compliance checks.

8.4 Professional Advisers

Lawyers, auditors, accountants, insurers and other professional advisers may access relevant information where required for legitimate professional services.

8.5 Regulators and Government Authorities

We may disclose information to competent regulators, law enforcement agencies, courts or government authorities where legally required or otherwise permitted.

8.6 Business Transfers

If FIFO Markets undergoes a merger, restructuring, acquisition or sale of relevant business assets, information may be transferred as part of that transaction, subject to applicable legal requirements and appropriate safeguards.

8.7 Introducing Brokers and Partners

Relevant information may be shared with an introducing broker or authorised partner only where necessary for the relevant service, supported by a lawful basis and consistent with applicable confidentiality and data protection requirements.

We require service providers handling personal information on our behalf to follow appropriate confidentiality and security obligations.

9. International Transfers of Personal Information

FIFO Markets may use technology providers, trading infrastructure, compliance services and payment providers located in different countries.

Consequently, personal information may be transferred to or accessed from jurisdictions outside the country in which you reside.

Where applicable law requires safeguards for international transfers, we will implement the appropriate measures, which may include an adequacy mechanism, contractual safeguards, consent where legally valid, or another permitted transfer mechanism.

We will take reasonable steps to ensure that personal information receives an appropriate level of protection when transferred internationally.

10. Data Security

FIFO Markets seeks to protect personal information against unauthorised access, disclosure, alteration, loss, misuse and destruction.

Depending on the system and information involved, safeguards may include:

• Access controls and role-based permissions.

• Authentication and account security measures.

• Encryption in transit and, where appropriate, at rest.

• Secure storage and transmission of verification documents.

• System monitoring and security logging.

• Backups and recovery procedures.

• Confidentiality obligations for authorised personnel.

• Security reviews and incident response procedures.

No website, application, network or electronic storage system can be guaranteed to be completely secure. We therefore cannot promise absolute security, but we will take reasonable measures appropriate to the risks and applicable legal requirements.

Clients are responsible for protecting their login credentials and promptly notifying us of suspected unauthorised account access.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including account administration, legal compliance, dispute resolution, fraud prevention and the establishment or defence of legal claims.

Retention periods may depend on:

• Whether your account remains active.

• Applicable AML, KYC and financial recordkeeping requirements.

• Regulatory obligations applicable to the relevant legal entity.

• Pending complaints, investigations or legal proceedings.

• Security, audit and transaction-record requirements.

When personal information is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to applicable law and legitimate retention requirements.

Closing your account does not necessarily require immediate deletion of all information.

12. Cookies and Similar Technologies

Our website and digital services may use cookies, pixels, local storage or similar technologies to:

• Keep sessions active.

• Remember relevant preferences.

• Improve website performance.

• Understand website usage.

• Support security and fraud prevention.

• Measure marketing effectiveness where permitted.

Where required, we will obtain consent before using non-essential cookies or similar technologies.

You may manage cookie preferences through the available website controls or your browser settings. Disabling certain cookies may affect the functionality of some services.

A separate Cookie Policy may provide further details about the technologies used.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Request confirmation of whether we process your personal information.

• Request access to your personal information.

• Request correction of inaccurate or incomplete information.

• Request deletion of information where legally applicable.

• Request restriction of, or object to, certain processing activities.

• Withdraw consent where processing relies on consent.

• Request a copy of certain information in a portable format where applicable.

• Opt out of direct marketing.

• Lodge a complaint with the relevant data protection authority.

• Request information about certain disclosures or international transfers, where required by law.

These rights are not absolute. We may need to retain or continue processing certain information to meet legal, regulatory, security or recordkeeping obligations.

To exercise your rights, contact support@fifomarkets.com. We may request reasonable information to verify your identity before responding.

14. Automated Processing and Risk Assessment

We may use automated systems and analytical tools to support identity verification, fraud detection, transaction monitoring, account security and compliance screening.

Where required by applicable law, we will provide relevant information about significant automated decisions and applicable rights to request review or challenge a decision.

Trading risk controls and automated security checks may affect account access or transaction processing where necessary. Any such action remains subject to applicable legal requirements and our contractual terms.

15. Children's Privacy

FIFO Markets's services are intended for adults who meet the applicable legal age and eligibility requirements for opening a trading account.

We do not knowingly seek to collect personal information from children for the purpose of providing trading services. If we discover that an account has been opened using information belonging to an ineligible minor, we may restrict the account and take appropriate steps in accordance with applicable law.

16. Third-Party Websites and Services

Our website, client portal or application may contain links to third-party websites or services.

These third parties may operate under their own privacy policies, terms and security practices. FIFO Markets is not responsible for the independent privacy practices of third-party services that we do not control.

Clients should review the relevant third-party privacy notice before providing personal information directly to that provider.

17. Marketing Preferences

You may opt out of promotional emails or other marketing communications by using the unsubscribe mechanism provided or by contacting us.

Opting out of marketing does not prevent us from sending essential communications relating to account security, KYC verification, deposits, withdrawals, trading activity, legal notices or other necessary service matters.

We will process marketing preferences in accordance with applicable law.

18. Personal Data Breaches

If a personal data incident occurs, FIFO Markets will assess the nature and potential impact of the incident and take appropriate steps to contain, investigate and remediate it.

Where required by applicable law, we will notify the relevant supervisory authority and affected individuals within the prescribed timeframes.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations or data processing practices.

The revised version will be published on our website or relevant digital platform with an updated revision date.

Where required by law, we will notify affected individuals of material changes or obtain any additional consent that may be necessary.

20. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal information, please contact us:

Company: FIFO Markets Financial Ltd

Email: support@fifomarkets.com

Client Portal: https://client.fifomarkets.com/login

Please include sufficient details to help us identify your request. Do not send passwords, private keys, wallet recovery phrases or unnecessary sensitive financial information by ordinary email.

21. Applicable Law

This Privacy Policy is intended to operate in accordance with the data protection laws applicable to the relevant FIFO Markets legal entity and the services it provides.

Where applicable, this may include the UAE Personal Data Protection Law, Federal Decree-Law No. 45 of 2021, and other relevant data protection legislation. Different rules may apply to entities established in certain financial free zones or to clients protected by other jurisdictions' laws.

Nothing in this Policy limits any mandatory privacy rights that cannot lawfully be excluded.

End of Privacy Policy