(Last Updated: 22/07/2025)
XBO TRADING (CANADA) LIMITED (“we”, “our” or “us”) operates the website https://www.xbramp.com and any subdomains and related features, as well as mobile applications (“Website”, and together with the Platform, the “Services”). We are dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fair. This Privacy Policy (“Policy”) was designed to help you better understand the information we collect, store, use and share, and it applies whenever you visit our Website, interact with our Platform, or otherwise access or use any of our Services.
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range of or with the best experience of using our Services.
This Policy is integrated into and forms part of our Terms of Use which are currently available in our website.
Depending on your interaction with us, we may collect two types of data from you:
“Non-Personal Data” meaning aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.
“Personal Data” or “Personal Information” (as these terms are defined under the applicable privacy laws) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.
For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
Further, please note that we collect or process Personal Data constituting or revealing biometric data, through our third-party electronic identity verification providers.
The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the applicable British Columbia Personal Information Protection Act applies):
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DATA TYPE
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METHODS AND PURPOSE
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LAWFUL BASIS
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Website Interaction and Marketing
When you interact with our Website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”). |
Online Identifiers are used in particular to operate the Website and enable its proper functionality, for example to automatically recognize you by the next time you enter the Website or to confirm you are a real person.
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Strictly necessary cookies (as described in the Cookies and Similar Technologies section below) which are required for the proper and basic operation of the Website will be processed in our legitimate interests, where such cookies collect Personal Data on our behalf. Other cookies, to the extent these collect your Personal Data, will be based on your consent which we will obtain through our cookie notice and consent mechanism.
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Contact Information
If you voluntarily contact us, through any means of communications we make available for support or other general inquiries you will be required to provide us with certain information such as your name, your organization name (i.e., on behalf of which you contact us), email address, and any additional information you decide to share with us (“Contact Information”). |
We process Contact Information to respond to your inquiry, and provide you with the support, materials and information you have requested. The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). We may also process Contact Information in order to meet our regulatory obligations or as required by law or regulation (KYC and AML regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.
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We process Contact Information subject to your consent. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of our Services. We may also process Contact Information in order to comply with our legal obligation.
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Job Application:
In the event you apply for a position and submit your CV we will process the information included in the CV and the application form, including name, email address and phone number, employment history and education. Also, where allowed or required by law, we may process diversity and inclusion data regarding your candidacy such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data (“Candidate Information”). |
We will use Candidate Information to process your job application and for recruitment purposes. Further, we may process Candidate Information in order to comply with corporate governance, legal and regulatory requirements (including the retention of such information).
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We process Candidate Information subject to your consent. We may also process it under our legitimate interest, which is performing a proper recruitment process for our candidates, record keeping and protection from potential legal claims. If we process Special Categories of Personal Data to ensure diversity, we will do so upon your explicit consent, which you may withdraw at any time by contacting us.
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Legal Matters
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We may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, to enforce our legal terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability.
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Such processing is based on our legitimate interests, which in this case are protecting our Services and data, exercising our legal rights, and complying with our legal obligations.
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Platform Account Information:
when you register an account with our Website (including any subsequent login to that account), contact us with inquiries, when you sign-up to receive e-mail updates and newsletters, or registering to receive our Services you may provide us Personal Data voluntarily, such as your name, user name, password, e-mail address, and your bio description. ("Platform Account Information") |
We Collect your Platform Account Information in order to provide you with our Services and to respond to your inquiries.
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We collect Platform Account Information based on your consent. Further processing may be subject to our legitimate interests, which are providing our Services.
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Financial Information:
as an integral part of joining and enjoying from our Platform, you will be required to provide certain financial information, including payment details information. Such information will be collected and processed by us and by the relevant service providers ("Financial Information"). |
We collect your Financial Information in order to provide you with our Services.
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We collect Financial Information based on your consent. Further processing may be subject to our legitimate interests, which are providing and improving our Services.
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Biometric Information:
as part of the Know Your Client and AML processes we will require you to provide us with certain biometric information ("Biometric Information"). |
We collect your Biometric Information in order to provide you with our Services.
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Our legal basis for processing Biometric Information is your explicit consent upon joining our Platform. Further processing will be subject to the performance of a contract with you.
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Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in the Data Transfer Section is based on the same lawful basis as stipulated in the table above.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services, as detailed above.
HOW WE COLLECT YOUR INFORMATION:
COOKIES AND SIMILAR TECHNOLOGIES:
Our Services and some of our service providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities. For additional information about the type of cookies we implement, please visit our Cookies Policy.
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your Personal Data with third parties, including our service providers that help us maintain our Services. More information about the categories of such third-party recipients is described below:
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CATEGORY OF RECIPIENT
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DATA THAT WILL BE SHARED
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PURPOSE OF SHARING
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Service Providers and Business Partners
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All types of Personal Data
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We may engage selected third-party companies and individuals to perform services complementary to our own (hosting services, data analytics services, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). In general, these Service Providers may have access to your pseudonymized Personal Data, Personal Data in connection with said hosting services, and data analytics services. However, for purposes regarding data and cyber security services, fraud detection, AML and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, as well as our business, legal, financial and compliance advisors will have access to the applicable Personal Data required for each respective purpose, and such may only be used for such purposes. Furthermore, we will share Personal Data with Modulr as part of our business partnership, including know your customer (KYC), customer due diligence (CDD) and AML/CTF-related Personal Data.
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Third Party Integrations
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All types of Personal Data
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Our Services allow you integrate with certain third-party services, in which case you will be bound by the terms of service and privacy notices of said third parties – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third-party services.
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Consent Manager (“CMP”)
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Online Identifiers and the user’s preference.
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When you browse our Website for the first time, depending on your location, a CMP will appear, where you will be able to choose if you allow us and our partners to implement tracking technologies, and where applicable, to share Personal Data (e.g., Online Identifiers) with third parties for one or all of the aforesaid purposes (“Preference”). These Preference are different depending on your jurisdiction. The CMP receives the Online Identifiers from us.
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Any acquirer of our business
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All types of Personal Data
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We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
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Legal and law enforcement
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Subject to law enforcement authority or other applicable legal requirement
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We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
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We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the information they receive and to use the information for pre-agreed purposes only while ensuring compliance with all applicable privacy and data protection regulations (such service providers may use other Non-Personal Data for their own benefit).
USER RIGHTS:
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, you have the right to control and request certain limitations or rights to be executed.
The following table describes all the rights you are entitled to:
Your rights may be exercised by contacting us via the contact details available below.
DATA RETENTION:
We retain the data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable laws, or until you express your preference to opt-out, where applicable.
The retention periods are determined according to the following criteria:
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice. However, retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time and in a way that prevents the Data from being restored or reconstructed.
ELIGIBILITY AND CHILDREN PRIVACY:
The Website is not intended for use by individuals under the age of majority, as defined by the applicable law in such individual’s jurisdiction of residence (“Minor“). We do not knowingly process Minor’s information and will discard any data we receive from a user that we find or reasonably suspect to be a Minor immediately upon discovery. Please contact us below if you have reason to believe that a Minor has shared any data with us.
SECURITY MEASURES:
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as minimizing the amount of data that we store on our servers, restricting access to Personal Data by Company employees, contractors, agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access.
Please contact us below if you feel that your privacy was not managed properly, or if you become aware of an attempt by a third party to gain unauthorized access to your Personal Data. We will make a reasonable effort to notify you and the relevant authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
INTERNATIONAL DATA TRANSFER:
We operate globally, and any information that we collect, disclose or share, including (but not limited to) your Personal Data, can be stored and processed in the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. To the extent that the GDPR or Data Protection Act 2018 and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR“) are applicable, we will only transfer or share your Personal Data to data recipients:
POLICY AMENDMENTS:
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. All changes will be effective immediately upon the display of the revised Policy. The updated date of this Policy will be reflected in the “Last Updated” heading, indicated at the header of the Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.
CONTROLLING VERSION:
This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.
CONTACT INFORMATION:
If you have any question, inquiry or concern related to this Policy or the processing of your Personal Data, you may contact our privacy team at [email protected].
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