Anti-Money Laundering Policy

CDO Markets (“CDO”), believes that maintaining our clients trust and confidence is a high priority. We understand that privacy is an important concern for both clients and visitors to our web site(s). Whether you are a client of CDO, or just visiting our web sites, we would like to take the opportunity to explain how we work to protect your privacy in the event we collect, retain and use information about you, and the steps we take to safeguard that information.

By registering for any services on this Web site or by providing any information to us, you consent to the collection, use and transfer of your information under the terms of this policy.

For the purposes of this Privacy Policy, “we”, “our” and “us” refers to CDO and any reference to “you” or “your” means you, the user.

Overview about visiting CDO website,

No personal information is retrieved from our servers when a client or visitor browses the public (pre-login) areas of our web sites. Although we may use web site usage data to improve the content and services offered to our web site visitors, such data is reported on an aggregate, anonymous basis with no personal information associated with such gathering of data. Typical data may include: how many people visit our web sites; the pages they visit; how long they stay on our web sites; and the domain name of the site visitors connect from e.g. google.com.

The use of Cookies

A Cookie is a small piece of information transferred to your hard drive by the web site to support your navigation of a web site. They are widely used throughout the web to assist users who repeatedly visit a particular web site or for tracking usage of a web site. Although CDO does not use cookies to gather personal information such as a person’s name or email address. We may, however, choose to use cookies to identify repeat visitors to our web sites, to determine the path visitors take to our web sites, and where appropriate identify visitors who came to our web site as a result of a banner ad on a third party web site. Please be assured that all information we gather by the use of a cookie is compiled on an aggregate, anonymous basis. With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. If you want to know how to do this please look at the help menu on your web browser. However, please note that “rejecting” cookies will mean that you may not be able to use certain features on our Web site. We therefore recommend that you accept all cookies in order to ensure you benefit from all of our web sites’ features and security mechanisms. Find out more about the use of cookies and on how to switch off cookies on http://www.cookiecentral.com or http://www.aboutcookies.org/controlcookies.asp

In the event you access a third party web site via a link on our pages then associated cookies might also be created when you access these sites. CDO will not have access to these cookies or any information that these cookies may contain. Although we would expect third parties to adhere to a suitable privacy policies and terms and conditions of use, we are not responsible for the actions or policies of such third parties. Accordingly, you should contact the third party site for more information on their policies regarding cookies.

CDO Data retention, security of information collected, internet based transfers and disclaimer

We will retain your information for a reasonable period or as long as the law requires. In accordance with the UK’s Data Protection Act 1998, we employ strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line.

Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. Therefore by browsing this Web site and communicating electronically with us, you acknowledge and agree to our processing of personal information in this way.

Whereas we employ reasonable measures to protect against viruses and other harmful components, the nature of the internet is such that it is impossible to ensure that your access to the Web site will be uninterrupted or error-free, or that this Web site, its servers or emails which may be sent by us are free of viruses or other harmful components.

Whether you are a CDO client or a visitor browsing our web sites, and you submit / request information from one of our non-public areas (login & password / token protected areas) such as our online account forms, or trading statements please note that we use Secure Sockets Layer (“SSL”) encryption technology to protect the information you submit. This technology helps protect you from having your information intercepted by anyone other than CDO while it is being transmitted to us. We strive to ensure that our web sites are and remain secure and that they meet the highest possible industry standards. In addition to SSL encryption technology, we use a variety of other safeguards such as firewalls, authentication systems (e.g. passwords, tokens etc) and access control mechanisms to control unauthorized access to our systems and data.

The contents of this Web site are designed to comply with the general obligations of the European Directives on Data Protection and E-Privacy. We cannot be responsible for non-compliance with any local advertising or other laws in relation to this Web site or its contents.

Security Procedures

CDO restricts access to Personal Information about you.

To protect the security of Personal Information, we maintain physical, electronic, and procedural safeguards that comply with regulatory standards for securing the information we collect about you. (as detailed previously).

The Use of Hyperlinks

CDO’s web site may contain hyperlinks or “links” to third party sites, and other sites may also “link” to our sites. Any web sites linking to and from our sites may have privacy practices different from CDO’s. Our web site Privacy Statement applies solely to information collected by our web sites. CDO is not responsible for the privacy policies or the content of sites you link to, and we have no control over the use or protection of information provided by you or collected by those sites. You should also be aware that where such site is located outside the EEA, there may be no equivalent legislation or privacy policy governing the use of personal data. If you choose 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 any information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

Personal Information (Non-Public)

In the event visitors to our web site choose to provide CDO with non-public personal information about themselves (e.g., name, address, phone number, email address) for the purpose of receiving additional information about our products and services, or if you are a CDO client and we obtain from you or from other sources non-public personal information about you in the course of providing you with our products and services, we will take the following steps to safeguard such non-public personal information (“Personal Information”).

Personal Information (Non-Public)

In order to provide you with financial products and services, or information about such services, CDO may collect the following types of Personal Information:

Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms) and every time you email us or provide us with your details in other ways (i.e. over the telephone, by fax, by mail etc.) . This information would include, but not be limited to, such details as: your name, address, landline or mobile telephone numbers, fax number, e-mail address, social security or national insurance number, your date of birth; company name and contact details; income, investment experience; details of the ways in which you are happy to receive information from us and/or selected third parties etc.
Information about your transactions with us, our affiliates, or others. This information could include your trading history through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.
Information automatically collected about your visit to our Web site. Information relating to your selection of a user ID for the use of some of our services or activities.
You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.

Use of Information Collected

We hold your personal information in order to open and manage your account with us, whilst also satisfying the key regulatory obligation of “Know your client”. In addition this information will enable us to review your needs on a regular basis thereby assisting us in providing you with the level of customer service you expect. It may also be used to provide you with new information or opportunities from us about our various products and services that we believe may be relevant to your needs.

Information We May Disclose

The personal information you provide may be accessed by or given to our staff and disclosed to unaffiliated third parties with which CDO is engaged in a joint marketing arrangement (see Who we may share your information with section below). The personal information disclosed to such unaffiliated third parties will include but not be limited to:

Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms) and every time you email us or provide us with your details in other ways (i.e. over the telephone, by fax, by mail etc.) . This information would include, but not be limited to, such details as: your name, address, landline or mobile telephone numbers, fax number , e-mail address, social security or national insurance number, your date of birth; company name and contact details; income, investment experience; details of the ways in which you are happy to receive information from us and/or selected third parties etc. Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide. Who we may share your information with

CDO may disclose the types of Personal Information listed above (see Information we may disclose section above) to the following types of third parties:

Companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell CDO products or services; Financial service providers, such as introducing brokers, broker-dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisors, and commodity pool operators; Publishers and other direct marketers of products related to the financial services industry, such as newsletter or book publishers and software or trading system developers; Government bodies and law enforcement agencies; Successors in title to our business; We may also disclose Personal Information to other non-affiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorised, You should be aware that countries outside the European Economic Area do not always have strong data protection laws. Therefore However In the event any transfer data is made to countries outside of the EEA, this will only be done to; countries with equivalent legislation and or organisations with the appropriate level of data security.

Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Accessing, Updating , Contacting Us and Your right to opt-out of information sharing

Under the Data Protection Act 1998, you are entitled to see the personal information we hold about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date.

Furthermore, if you prefer that we not disclose your Personal Information to unaffiliated third parties, you can choose to opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). However, this opt out will not apply to Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any transaction in your account(s) with us (if applicable).

If you:

wish to correct or update the personal information that you have provided to us; choose to opt out of any communications that you may have initially agreed to receive; wish to opt out of disclosure to non-affiliated third parties; or if you have any comments, queries or requests relating to our use of your personal information or any questions about this privacy policy, please contact operations@cdomarkets.com We welcome your questions and any suggestions you may have about our privacy policy. However, we are entitled by law to charge a small administrative fee to meet our costs in providing you with details of the information we hold about you and we may require proof of your identity before we supply the information to you.

Online Services

If you register for any of our online products or services, we will retain your user ID and password and other information about your use of our web site in order that we may recognise you as a registered user. We may also obtain your email address from you or from another source. We may send you email offers for our as well as our affiliates’ products and services. You may also receive emails from third party product and service providers we think may be of interest to you. All email offers we send to you include an opportunity to opt out from future email offers.

If you opt out from receiving email offers, we reserve the right to still send (via email or otherwise) important information about your account(s) with us (if applicable) and our products and services.

Web Site Privacy Statement Updates

As and when necessary we reserve the right to make changes to our Privacy Statement. We recommend that regular visitors to our web sites review this Web site Privacy Statement periodically to learn of any updates and changes that have been made to this Statement. Should you become a CDO client by obtaining a user ID and password by completing account forms on-line, we will notify you of any changes we make to this Statement in the following manner. The first time you log on to a non-public part of our web site after we have modified our Web site Privacy Statement, you will be required to click-through our revised Statement. Accessing your account information or placing an order will not be possible until you agree to the terms of the revised Statement