California Privacy Policy

Last Material Update: 22 January 2021


Welcome to’s Privacy Policy under the California Consumer Privacy Act ("California Privacy Policy").

We respect your privacy and we are committed to protecting your personal information. This California Privacy Policy will inform you as to how Foris DAX Global Limited, a company incorporated under the laws of Ireland, with a registered address: 70 Sir John Rogersons Quay, Dublin 2, Ireland, ("", we, us, our) look after your personal information when using any of our products, services or applications (together the "Services") or when visiting or using our websites: and ("Site") or mobile application ("App").

This California Privacy Policy tells you about your privacy rights and how the California Consumer Privacy Act and its inherent California General Attorney Regulations protect you.

If you are not a California resident, please check our Global Privacy Notice.


  1. Important informationa and who we are
  2. The data we collect about you
  3. How is your personal data collected?
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Personal Data retention
  9. Your legal rights
1. Important information and who we are
Purpose of this California Privacy Policy

This Privacy Policy also describes your privacy rights and how you can exercise these rights with us.

It is important that you read this Privacy Policy together with any other privacy notice, fair processing notice, or just-in-time notice that we may provide on certain occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements but is not intended to override those other notices.

Data Protection Officer, Complaints and Contact details

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this California Privacy Policy. If you have any questions or complaints about this California Privacy Policy, our privacy practices or if you have a request to exercise your rights, please contact our DPO Team in the following ways:

Email: [email protected]

Phone (toll free): +1 888-959-8091

In addition, you have the right to make a complaint about the way we process your personal information to:

  • the Data Protection Commission (DPC), Ireland’s supervisory authority for data protection matters and/or
  • to the local privacy regulator in California.

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority or the local privacy regulator, so please feel free to contact us in the first instance.

Changes to the California Privacy Policy and your duty to inform us of changes

We review and update our Privacy Policy from time to time.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

Third-party links

The Site and App may include links to third-party websites, plug-ins and applications ("Third Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements. When you leave our Site or App, we encourage you to read the privacy notice of every Third Party Site you visit or use.

2. The data we collect about you

Personal information, means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de – identified data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped in categories as follows:

Category of Personal Information Specific Pieces of Personal Information
Identity Data
  • first name,
  • maiden name,
  • last name,
  • username or similar identifier,
  • title,
  • date of birth and gender,
  • a visual image of your face,
  • tax identification number,
  • national identity cards,
  • passports or other form of identification documents including proof of address such as utility bill or bank statement.
Contact Data
  • billing address,
  • delivery address,
  • home address,
  • work address,
  • email address and telephone numbers.
Financial Data
  • bank account,
  • payment card details.
Transaction Data
  • details about payments to and from you,
  • other details of any transactions you enter into using products and services you have purchased from us.
Investment Data
  • information about your:
    • investment objectives,
    • investment experience,
    • prior investments.
Technical Data
  • internet protocol (IP) address,
  • your login data,
  • browser type and version,
  • time zone setting and location data,
  • browser plug-in types and versions,
  • operating system and platform, and
  • other technology or information stored on the devices you allow us access to when you visit the Site or use the Services, such as friends lists or other digital content.
Profile Data
  • your username and password,
  • requests by you for products or services,
  • your interests, preferences, feedback and survey responses.
Usage Data
  • information about how you use:
    • our Site,
    • App,
    • products and services.
Marketing and Communications Data
  • your preferences in receiving marketing from:
    • us
    • our third parties
    • your communication preferences.

As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors, to check your identity for onboarding purposes. This data falls within the scope of special categories of data (see Special Categories of Data below). When we ask to collect a visual image of your face you will be asked for your specific consent. You can refuse to provide this, but it means that we will be unable to register you and provide you with the Services.

Special categories of personal information are data revealing your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. We will only use special categories of personal information for a specific purpose and if we are able to satisfy both the Lawful Basis requirements, as well as at least one of the following additional conditions:

  • You have given explicit consent;
  • Processing relates to personal information which are manifestly made public by the data subject;
  • Processing is necessary for the establishment, exercise of defence of legal claims, or
  • Processing is necessary for reasons of substantial public interest based on EU or EU Member State Law.

We are subject to the EU Anti-Money Laundering Directives 4 and 5 and the relevant EU Member States' law implementing them which require us to process for instance information from your ID documents including a photographic picture of you. See also row iv, in the table which describes the purposes for which we will use your personal information.

We also collect, use and share Aggregate Consumer Information such as statistical or demographic data for any purpose. Aggregate Consumer Information could be derived from your personal information but is not considered personal information in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Consumer Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this California Privacy Policy.

If you refuse to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal information collected?

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal information you provide when you:

  • apply for our products or services;
  • create an account;
  • subscribe to our services or publications;
  • make use of any of our Services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We will also collect Transaction Data and Investment Data. We may also receive Technical Data about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies through the Cookie Settings.

Third parties or publicly available sources. We also obtain information about you from third parties (such as employers, credit reference agencies and fraud prevention agencies) who may check your personal information against any information listed on other databases.

4. How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • For the provision of the Services.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • For business purposes we disclose your personal information as described in Section Disclosures of your personal information.
  • Sale of Personal Information

When you use our Services, our authorized partners may collect categories of Personal Information about you and use this data for their own purposes. This activity may qualify as a sale under the CCPA. You can make choices to allow or prevent such uses. Depending on your choices, during the past twelve months, we may have sold information within the categories defined in the table under Section 2.

Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. See below for further details on marketing.

Purposes for which we will use your personal information

We have set out below, in a table format, an illustrative example of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

No Purpose/Activity Categories of personal information Lawful basis for processing including basis of legitimate interest
i. To register you as a new customer
  • Identity
  • Contact
  • Financial
  • Performance of a contract with you
  • Necessary to comply with a legal obligation (e.g. to comply with Anti-Money Laundering requirements)
  • To process and deliver our Services and any App features to you including:
    • Execute, manage and process any instructions or orders, you make
    • Manage, process, collect and transfer payments, fees and charges
    • Collect and recover money owed to us
  • Identity
  • Contact
  • Financial
  • Transaction
  • Technical
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (e.g. to prevent abuse of our Services and promotions)
  • To manage our relationship with you which will include:
    • Notifying you about changes to our terms or Privacy Policy/Notice
    • Asking you to leave a review or take a survey
    • Keep you informed of our company's business and product development
  • Identity
  • Contact
  • Profile
  • Transaction
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated, study how our customers use our products/services and how prospective customers respond to our marketing campaign)
  • To manage risk and crime prevention including:
    • Detect, investigate, report and prevent financial crime in broad sense
    • Obey laws and regulations which apply to us
    • Responding to complaints and resolving them
  • Identity
  • Contact
  • Financial
  • Technical
  • Transactional
  • Investment Data
  • Special Categories Data that you give us directly or that we receive from third parties and/or publicly available sources:
    • special categories data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);
    • special categories data that is revealed by photographic ID although we do not intentionally process this personal information;
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to develop and improve how we deal with financial crime)
  • For Special Categories Data it's necessary for reasons of substantial public interest under the EU Anti-Money Laundering Directives 4 and 5 and the relevant EU Member States' laws implementing them.
v. To enable you to partake in a prize draw, competition or complete a survey
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaign and growing our business)
vi. To administer and protect our business, our Site and App(s) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
  • Identity
  • ontact
  • Financial
  • Technical
  • Transactional
  • Investment Data
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
  • Necessary to comply with a legal obligation
vii. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
viii. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy)
ix. To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Investment Data
Necessary for our legitimate interests (to develop our products/services and grow our business)
x. Relevant for individuals related to partnering companies
  • Corresponding with partnering organizations
  • Invoicing, billing and other business enquiries related to the partnering organizations
  • General management of relationships with partnering organizations
  • Identity (partially)
  • Contact (partially)
  • Performance of a contract with partnering organizations
  • Necessary for our legitimate interests (to develop our products/services and grow our business)


We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Transactional, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or sending a message to [email protected].

When you opt-out of receiving these marketing messages, this will not apply to messages related to a product / service transaction, maintenance of our systems or product / service experience.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please refer to our main website.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. Disclosures of your personal information

We may share your Personal Information with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies and affiliates in order to complete tasks, provide the Services to you on our behalf, and otherwise fulfill our obligations. We require third-party service providers, under written agreements, to respect the security of your Personal Information and to treat it in accordance with applicable law.

We may share your Personal Information and other data you provide to us for the following purposes:

  • To verify your identity.
  • To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.
  • To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
  • To improve our information, technology, and security systems including websites and mobile applications.
  • To provide customer service.
  • To promote our products or Services if you submit a product review or post content on public areas of our product, Services, or social media accounts.
  • To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
  • To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.
  • To evaluate, effectuate, or otherwise transfer your Personal Information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.

We may have disclosed or sold the following categories of Personal Information to the following categories of third parties

Categories of Third Parties Categories of Personal Information
Companies and organizations that assist us in processing, verifying or refunding transactions Identity Data, Financial Data, Transaction Data
Identity verification agencies Identity Data
Fraud prevention agencies Identity Data, Financial Data, Transaction Data
Organizations which assist us with customer service facilities; Identity Data
Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant Terms & Conditions governing the use of any of the Services; All the categories in the table under Section 1 above.
Regulatory and law enforcement authorities, where the law allows or requires us to do so. The categories would depend on legal grounds of the request.

Considering the nature of customers’ on-boarding verification process, we do not have an actual knowledge of selling Personal Information of minors under 16 years of age.

6. International transfers

To learn more about International Transfers, please click here.

7. Data security

To learn more about International Transfers, please click here.

8. Personal Information retention
How long will you use my personal information for?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transactional Data) for at least 5 years. For example, under the EU Anti-Money Laundering legislation (Anti-Money Laundering Directives 4 and 5) we are obliged to retain your personal information for a period of 5 years after the end of the relationship between us as a company and you as a customer.

For the purpose of defending our legitimate interests against possible legal claims, please note that correspondence (e.g. email addresses and content, chats with the customer service team, call recordings etc.) will be kept up to 10 years, depending on the limitation period (a limitation period is a time period during which a claim can be made) applicable in your country, after the end of the relationship between us as a company and you as a customer.

Another example relates to our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal information for the time of the promotion in order to prevent the appearance of abusive behavior.

Please note that under certain condition(s), you can ask us to delete your personal information. In some circumstances we will de-identify your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under applicable law in relation to your Personal Information:

  • Right to know about Personal Information collected, disclosed, or sold. ("Verifiable Consumer Request to Know").
  • Request correction of your Personal Information.
  • Request erasure / deletion of your Personal Information. ("Verifiable Consumer Request to Delete").
  • Right to opt-out of the sale of your Personal Information.

If you wish to exercise any of the rights set out above or if you want to raise a question or a concern about our privacy policy and practices, please contact us at [email protected], or at our toll-free telephone number. If you want to use an authorized agent to make a request, please contact us using the contact details provided above.

We will promptly take steps to disclose and deliver to you, free of charge, your Personal Information according to your Verifiable Consumer Request to Know. We may also contact you to ask you for further information in relation to your request to speed up our response.


You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.

Under certain circumstances, you may have rights under applicable law in the European Union, please click here.

If you want to make a request under the California Consumer Privacy Act through a natural person or a business entity authorized to act on your behalf, please beforehand contact us and in a timely manner we will provide you with a reply on how to designate such a person.