Last Updated: July 2020
By creating an account on the FiveWest Trading Site or by otherwise submitting Personal Information to us through the FiveWest Trading Site, you give your consent to the collection and use of your Personal Information as explained in this Policy. All capitalized terms used but not defined in this Policy have the meaning given to them in our Terms of Service.
Types of Information We Collect
The information we collect and maintain about you is provided during your onboarding as a user and during your entering into transactions with FiveWest in the context of a digital currency or other financial asset trades.
This Personal Information, not available publicly, comes from the following sources:
- Information you provide to us when you fill out account opening documents,
- complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number,
- investment objectives,
- investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details,
- telephone number,
- e-mail address and
- similar information;
- Information from your transactions with us,
- such as your trade amount,
- digital currency type, trade direction,
- sale proceeds or investment amount,
- and wire instructions; and Any other identifying information we collect in fulfillment of our “Know Your Customer” and sanctions screening legal and regulatory requirements, including, without limitation, Section 29 Financial Intelligence ACT, which requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
This federal requirement applies to all FiveWest counterparties and collected information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities. How We Protect Your InformationWe limit access to the Personal Information you provide us to those employees who need access to that information to provide you with services related to the transactions you are entering with FiveWest. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information. We use software, systems and procedures meeting generally accepted industry information security standards to protect your personal, financial and historical transaction information. While no security system is impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
The Importance of Being Accurate If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services, to ensure security and to comply with legal and regulatory requirements. 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 and maintain your trading information. This information helps us improve our services to you.An Ongoing Commitment to Your PrivacyWe are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you close your account with us, FiveWest will retain your information for regulatory compliance, internal record-keeping and other legal purposes.We Limit the Sharing of InformationTo protect your privacy, we limit the sharing of your Personal Information outside of FiveWest. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:
To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties, including TradeBlock, to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you enter into a financial transaction through the FiveWest Trading Site, we share your Personal Information with third party service providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform transaction execution and clearing services on your behalf. Pursuant to our agreements with these service providers, their ability to use your Personal Information is specifically limited to the service being provided.As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.FiveWest may share information with our affiliates if the information is required to provide the services you request. An affiliate is a company that we own or control, or with which there is common ownership with us.FiveWest also reserves the right to disclose your Personal Information where required by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.Reviewing, Changing or Correcting InformationYou are responsible for helping us to maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete.