Privacy Policy
Spot FX (“COESfx”) is dedicated to serving your financial needs. Your privacy as well as your confidence in every aspect of our banking relationship is important to us.
This Privacy Notice is intended to assist you in understanding our policies and practices about handling customer information.
In this disclosure the terms “we”, “us”, “our’, ” or “Spot FX CLEARING” means Spot FX Clearing Corp. The terms “you” and “your” mean you, our customer. The term “information” means nonpublic, personal financial information that we may have on record about you.
CONFIDENTIALITY and SECURITY
We do not reveal specific information about customers or their accounts to non-affiliated third parties with the following exceptions:
* If you request in writing that we provide it to another party;
* If the information is provided to help complete a transaction initiated by you (for example, to complete an ATM or debit card transaction or so we can have your check orders printed);
* If the information is required for legitimate Spot FX Clearing use, in accordance with applicable law and standard banking practices (for example, information provided to our attorneys, collection agencies, and credit reporting agencies for the purposes of making a loan, collecting a debt, verifying a customer’s account(s) or existence, or for marketing firms conducting surveys on our behalf);
* If the information is required or allowed by law (for example, a subpoena or court order to produce records regarding the customer’s account relationship with the FCM.) In such instances, information provided is limited to that required or allowed by law;
* If the information is required by a FCM auditor or examiner for the purpose of completing an official audit or regulatory examination of the Spot FX Clearing; and
* To make available products or services that are offered by a non-affiliated third party that is under contract to provide these services.
ACCOUNT NUMBERS and CODES
We will not disclose your account number or any access code for a savings account or checking account to a non-affiliated third party in order for them to sell you products or services. SPOT FX CLEARING does report to consumer reporting agencies various information on your payment history on loans you may have with us, which may include your loan account number. We are allowed or required to do so by law.
INFORMATION WE MAY COLLECT
The personal information we collect from your transactions with us and with affiliated companies in the Spot FX Clearing family, which we collect and may disclose about you, comes from the following sources:
* Information we receive from you on applications and other forms, such as your name, address, and telephone number,
* Information about your transactions with us, our affiliates, or non-affiliated third parties, such as your account balances, payment history, and account activity
* Information we receive from a consumer reporting agency, such as your credit bureau reports and other information relating to your creditworthiness, and
* Information we receive about you from other sources, such as your employer and Other third parties
We may disclose any of the above information that we collect within the Spot FX Clearing family of companies (our affiliates) and with non-affiliated third parties as described below.
INFORMATION WE MAY SHARE
We may share all of the information we collect about you with the following types of “affiliates” (i.e., companies related to us by common control or ownership) and “non-affiliated” third parties” (i.e. third parties that are not members of our corporate family)
* Financial service providers; such as mortgage bankers, securities broker-dealers and insurance agents;
* Non-financial companies; such as retailers, direct marketers, airlines and publishers; and
* Others, such as non-profit organizations.
We believe that being able to offer you additional products and services which may interest you and will best meet your needs. We believe that this is benefit to you and may save you both time and money. To do so, we may share identification information (such as name and address), transaction and experience information (such as payments), credit eligibility information (such as credit reports and applications) and other information.
If you prefer that we not disclose nonpublic personal information about you to such non-affiliated third parties (with respect to this loan or account), you may opt-out of those disclosures, that is, you may direct us not to make those disclosures (other than those permitted by law). If you wish to opt-out of disclosures to non-affiliated third parties, you will need to complete the attached opt-out notice and forward same to SPOT FX CLEARING.
In addition we may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing arrangements:
* Information we receive from you on applications or other forms, such as your name, address, social security number, assets and income;
* Information about transactions with us, our affiliates or others, such as your Such as your account balance, payment history, parties to
Transactions and credit card usage; and
* Information we receive from credit bureaus, such as your Creditworthiness and your payment history.
We are also permitted by law to share information about our experiences or transactions with you or your account (such as your account balance and your payment history with us) with our affiliates. We also may share additional information about you or your account (such as information we receive from you in applications and information from credit reporting agencies) with our affiliates. You may direct us not to disclose to our affiliates information that does not relate solely to our or our affiliates’ experiences or transactions with you or your account (such as the application information and credit bureau information) by completing the opt-out notice and forwarding same.
We are also permitted by law to share information about you with other companies in certain circumstances. We may disclose all the information we collect with companies assisting us in servicing your loan or account, with government entities in response to subpoenas or regulatory requirements, and with consumer reporting agencies.
If you decide to “opt-out”, please understand that we will continue to share information in these additional circumstances.
In order to better serve you, we may also retain information about the types of products and services that you purchase from us to learn about your financial needs and interests. This may include information that you share with us electronically. We may share this information with others to the extent permitted by law and in accordance with our information sharing policies and practices listed in this disclosure.
SPOT FX CLEARING maintains appropriate security safeguards and procedures regarding customer information. This includes the use of passwords and access codes to prevent revealing sensitive customer information to inappropriate or unauthorized sources. Information that we have about you is
Available to our employees and agents so they can service our customers. SPOT FX CLEARING prohibits our employees and agents from giving information about you to anyone in a manner that would violate any applicable law or our privacy policy. Our employees are trained to protect information we have about you. SPOT FX CLEARING also reviews compliance with this privacy policy.
Please be assured that whenever we use a third party company to provide services to us or on your behalf, we contractually bind them to strict confidentiality with respect to any information that we may have provided, including information about our customers.
HOW YOU CAN “OPT-OUT”
Under Federal Law, you my choose to “opt-out” of our sharing of information about you with certain non-agent, non-affiliated third party companies and persons. You may do this at anytime. To “opt-out”, you should complete, sign, and return the form we provide you, requesting us to stop sharing information. The form to “Opt-out” can be obtained at any one of our branch offices, or by emailing us at compliance@COESfx.com
Once your request is received, we have a reasonable amount of time to stop the information sharing. If any of your accounts are joint accounts, any one joint owner may make this decision to affect that particular account. To revoke your “opt-out”, send us your signed statement stating that you will permit us to share the information indicated.
PLEASE NOTE
If your customer relationship with SPOT FX CLEARING is ended for any reason, we will treat the information we have about you as if you were still our customer
SPOT FX CLEARING makes every effort to maintain the most up-to-date, complete and accurate customer and account information.
If you believe any information retained by SPOT FX CLEARING is inaccurate or contains incomplete information about you, please call us at 1-866-430-COES and ask for Privacy Coordinator.
We will investigate the problem and if it is determined that the information is incorrect, we will take appropriate action quickly and according to industry practices and applicable law.
If you have any questions regarding Privacy issues or policies, or if there are any concerns about the protection of your information, please feel free to contact our Privacy Coordinator at 1-866-430-COES.
“OPT-OUT” NOTICE
As was stated in our Privacy Disclosure, Spot FX Clearing Corp. may share certain information we collect about you with non- affiliated companies. SPOT FX CLEARING believes that this sharing is very important so that we can make available to you the many financial services our customers want and need.
Under Federal Law, you have the right to “opt-out” of our sharing of information with non-affiliates. If you request to “opt-out”, SPOT FX CLEARING will refrain from sharing any information about you with these non-affiliated parties (other than disclosures permitted by law).
Under the Fair Credit Reporting Act, you have the right not to have credit information about you shared among the companies in the Spot FX Clearing family. To exercise this right, you will need to complete the “Opt-Out” notice and forward same to us.
Even if you choose to ask us to refrain, you cannot “opt-out” from disclosures required by law or disclosures permitted by law to allow Spot FX Clearings to complete a transaction indicated by you or if the information is required for legitimate Spot FX Clearing use, in accordance with the law.
Remember, if you do not wish to “opt-out” you do not need to take any action at this time.
Your request to “opt-out” will apply to all your account relationships with SPOT FX CLEARING. If any account is a joint account, any one joint owner may make this decision to affect that particular account. Please allow one complete statement cycle for your request to take effect.
For your convenience, our web site may allow you to transfer to sites maintained by other organizations. Please be aware that the privacy policies of those organizations, and not that of Spot FX Clearing govern any personal information you release on such linked Internet sites.