1.1. Protecting the privacy and safeguarding the personal and financial information of our clients

and Web site visitors is one of our highest priorities. The following Privacy Statement explains

how we collect and protect your information. By opening an account or by using our Web site,

you give your consent to the collection and use of personal information by us as explained in

this privacy statement.

1.2. For the purpose of the Data Protection Acts, 1988 and 2003, the data controller is Commint Trader (“we”, “us”, “our”).


2.1. We collect information required to open an account, to transact business effectively and to

safeguard your assets and your privacy. To do this, we gather information to help us assess

your needs and preferences.

2.2. The information we collect directly from you includes information required to communicate

with you, including your name, mailing address, telephone number, e-mail address and to

identify who you are. We also collect demographic information when you open an account,

including, birth date, education, occupation, etc. and information about your transactions

with us. We also assess your trading experience, your approximate annual income and

approximate net worth to assess your financial position.


We use personal information only as appropriate to provide you quality service and security.

For example, we may use the information collected from you to verify your identity and

contact information. We may also use this information to establish and set up your trading

account, issue an account number and a secure password, maintain your account activity,

and contact you with account information. This information helps us improve our services to

you, customize your browsing experience and inform you about additional products, services

or promotions that may be of interest to you.


We may share information with affiliates if the information is required to provide the

product or service you have requested or to provide you the opportunity to participate in

the products or services our affiliates offer. We may also forge partnerships and alliances,

which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our clients. In order to ensure that these

products and services meet your needs and are delivered in a manner that is useful and

relevant, we may share some information with partners, affiliates and alliances. This allows

them to better understand the offers that are most relevant and useful. The use of your

personal information is limited to the purposes identified in our relationship with the

partner or affiliate.


5.1. We do not sell, license, lease or otherwise disclose your personal information to any third

party for any reason, except as described below.

5.2. We reserve the right to disclose your personal information to third parties where required by

law to regulatory, law enforcement or other government authorities or when necessary to

protect our rights or property.

5.3. To help us improve our services to you, we may engage another business to help us to carry

out certain internal functions such as account processing, order fulfilment, client service,

client satisfaction surveys or other support services or data collection activities relevant to our

business. Information we collect from you may also be transferred to, and stored at, a

destination outside the European Economic Area (“EEA”) including the United States. It may

also be processed by staff operating outside the EEA who work for us or for one of our

suppliers. We may also provide a party with client information from our database to help us

to analyse and identify client needs and notify clients of product and service offerings. Use of

the information shared is strictly limited to the performance of the task we request and for

no other purpose. All third parties with whom we share personal information are required to

protect personal information in a manner similar to the way we protect personal information.


6.1. All information you provide to us is stored on secure servers. Any payment transactions will

be encrypted using SSL technology. Where we have given you (or where you have chosen) a

password which enables you to access certain parts of our Web site, you are responsible for

keeping this password confidential. We ask you not to share a password with anyone.

6.2. Unfortunately, the transmission of information via the Internet is not completely secure.

Although we will do our best to protect your personal data, we cannot guarantee the security

of your data transmitted to our Web site; any transmission is at your own risk. Once we have

received your information, we will use strict procedures and security features to try to prevent

unauthorised access.


If at any time you choose to purchase a product or service offered by another company, any

personal information you share with that company will no longer be controlled under our

Privacy Statement. We are not responsible for the privacy policies or the content of sites we

link to and have no control of the use or protection of information provided by you or

collected by those sites. Whenever you elect to link to a co-branded Web site or to a linked

Web site, you may be asked to provide registration or other information. Please note that

the information you are providing is going to a third party and you should familiarize

yourself with the privacy policy provided by that third party.


8.1. We may use your data to provide you with information about our goods and services which

may be of interest to you and we or our agents may contact you about these by post and


8.2. If you are an existing customer, we will only contact you by electronic means (such as email,

voicemail or SMS) with information about our goods and services similar to those which were

the subject of a previous sale to you.

8.3. If you do not want us to use your data in this way please tick the relevant boxes when we

collect your marketing preferences. You may change your preferences at any time by

contacting a Client Services representative. An opt out election made by one account owner

of a joint account is applicable to all account owners of the joint account. An opt-out election

must be made for each separate account you hold with us.


9.1. We use cookies to assist us in securing your trading activities and to enhance the performance

of our Web site. (Cookies are small text files sent from the Web server to your computer.)

Cookies used by us do not contain any personal information nor do they contain account or

password information. They merely allow the site to recognize that a page request comes

from someone who has already logged on.

9.2. We may share Web site usage information about visitors to the Web site with reputable

advertising companies for targeting our Internet banner advertisements on this site and other

sites. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note

the pages you have visited. The information collected by the advertising company through the

use of these pixel tags is not personally identifiable.


You have the right to request a copy of the information held by us about you. We may

charge a fee for this which will not exceed €6.35. You also have the right to access your data,

have changed any inaccuracies in the details we hold about you, the right to object to the

use of your data and the right to block any specific uses of your data, by means of a request

in writing to Commint Trader.


From time to time, we may update this Privacy Statement. In the event we change this

Privacy Statement, the revised Privacy Statement will promptly be posted to the Web sites

and we will post a notice on our Web sites informing you of such changes. You agree to

accept posting of a revised Privacy Statement electronically on the Web site as actual notice

to you. Any dispute over our Privacy Statement is subject to this notice and our Customer

Agreement. We encourage you to periodically check back and review this policy so that you

always will know what information we collect, how we use it, and to whom we disclose it. If

you have any questions that this statement does not address, please contact a Client

Services representative.