Who is responsible for your data?
Introvisory Ltd, trading as FundFX, is the controller of personal data collected through this website and our services.
Introvisory Ltd, 105-107 Farringdon Road, London EC1R 3BU. Company number 11003625. ICO registration number to be confirmed. To contact us about your data, call 020 7566 0044 or email us.
What data do we collect?
Business contact details, information about your fund and its FX needs, trade data you share for a cost review, and basic technical data when you send a form.
- Contact details: name, role, organisation, work email and phone number.
- Fund details: fund type, domicile, currencies, approximate FX volumes and current provider type.
- Quote details: currency pair, amount, product, value date and settlement needs.
- Trade data for cost reviews: dates, times, currency pairs, amounts, rates and fees. We ask you to remove account numbers and counterparty names before sending.
- Call requests: preferred dates and times.
- Technical data sent with a form: IP address, browser user agent and the page you came from, kept to help prevent fraud and abuse.
- Analytics data, unless you turn analytics off: pages viewed and how the site is used, collected by Google Analytics.
We do not collect fund KYC documents. Those go straight from your fund to the provider.
Why do we use it, and on what lawful basis?
Mostly to provide the service you asked for and to run our business, which are our legitimate interests or steps you have asked us to take before a contract.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Replying to enquiries and call requests | Contact details, message, preferred times | Legitimate interests in responding to business enquiries |
| Running blind quotes | Quote details, fund type and domicile | Steps you ask us to take before entering into a contract, and legitimate interests |
| Running cost reviews | Trade data, contact details | Steps you ask us to take, and legitimate interests |
| Introducing your fund to a provider | Contact details and the fund details the provider needs | Your instruction, and legitimate interests |
| Preventing fraud and abuse of our forms | IP address, user agent, referrer | Legitimate interests in keeping our services secure |
| Occasional guides and updates to business contacts | Name, work email | Legitimate interests, with an opt-out in every email |
| Website analytics | Analytics cookie data | Legitimate interests in understanding how the site is used, with a one-click opt-out |
| Meeting legal and regulatory duties | Records of enquiries, approvals and complaints | Legal obligation |
Who do we share it with?
Providers only when you ask us to introduce you, and only what they need. Otherwise only our own service providers and anyone the law requires.
- Providers on our panel, once you choose one and ask us to introduce your fund. The provider then becomes a controller of the data it receives.
- Companies that host our website, database and email, under contracts that require them to protect the data.
- Google, which processes analytics data on our behalf, unless you turn analytics off.
- Regulators, law enforcement or courts where the law requires it.
We do not sell personal data.
How do blind quotes protect your fund's identity?
Providers receive the requirement, not the requester. They see the currency pair, amount, product, value date, settlement needs, fund type and domicile, but not your fund's name, your name or your contact details.
Your identity is shared only when you ask us to introduce you to a particular provider. What providers see at each stage
How long do we keep data?
Only as long as we need it. Uploaded trade files are deleted automatically 90 days after we receive them.
| Data | How long we keep it |
|---|---|
| Uploaded trade files for cost reviews | 90 days from receipt, then deleted, or sooner if you ask |
| Trade details entered on the website | 90 days from receipt, then cleared |
| Enquiries that do not lead to an introduction | 2 years from the last contact |
| Records for funds we introduce | 6 years after the relationship ends |
| IP address and user agent sent with forms | 12 months |
| Complaints | 6 years after the complaint is closed |
Is data sent outside the UK?
Only analytics data, unless you turn analytics off, because Google may process it outside the UK.
Google relies on the UK International Data Transfer Addendum or the UK Extension to the EU-US Data Privacy Framework for these transfers. Our website and database are hosted in the UK.
How do we protect it?
Uploaded trade files are encrypted when stored and kept outside the website itself, access is limited to the FundFX team, and data is deleted on schedule.
Forms are protected against automated misuse, the website uses an encrypted connection, and we never ask you to send account numbers or payment details through it.
What are your rights?
You can ask to see, correct or delete your data, object to how we use it, restrict it, or take a copy, and you can turn analytics off at any time.
To use any of these rights, call 020 7566 0044 or email us. We will reply within one month. You can turn analytics off with one click using the link in the footer or on our cookie policy.
How do you complain about how we use your data?
Tell us first and we will try to put it right. If you are not satisfied, you can complain to the Information Commissioner's Office.
See our complaints page for how we handle data protection complaints. The ICO can be contacted at ico.org.uk/make-a-complaint or on 0303 123 1113.
Will this policy change?
If it does, we will update this page and the date at the top.