We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will take steps to ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
We are Committed to Client Privacy
ThinkForex operates a client qualification policy that is intended to ensure that new Australian resident clients are adequately qualified to trade in any product offered through ThinkForex.
In order to be deemed sufficiently qualified to trade with ThinkForex, potential clients must prove that they are able to satisfy one of the three following criteria:
1. Sufficient Trading Experience
In order to establish that an individual has had sufficient trading experience, potential clients must prove all of the following. That they:
If a potential client fails to completely satisfy all three of the above criteria, then they either attempt the quiz (part 2) or attend a training course (part 3)
2. Multiple-choice quiz:
n order to qualify as a potential client for ThinkForex, you must record a pass score (of 70% or greater). The quiz consists of 10 (ten) multiple choice questions, with at least one correct answer required from each of the following sections:
If a mark of 70% or greater is achieved, you will be deemed qualified to trade through ThinkForex. If a pass grade is not achieved, then you will be required to complete a training course, as per part 3.
3. Training Course:
To be deemed eligible to trade with ThinkForex, an individual must undertake and complete a training course that satisfies the following criteria:
If a training course fulfills all three of the above requirements, then an individual will be deemed qualified to trade with ThinkForex.
If you cannot fully satisfy one of the aforementioned elements, then you will not be considered qualified to be a client with ThinkForex.
* Call ThinkForex for clarification regarding the eligibility of your provider.
** To be considered ‘actively operating’ as a trader, you must have made at least 20 trades during the time that your account has been open, and you must be assessed for compliance by providing your trading statement to ThinkForex.
The minimum opening balance requirement for all ThinkForex accounts is $250 AUD.
ThinkForex provides credit card funding for the ease of providing secure electronic payment system to its clients. This is used for both instantaneously funding accounts and meeting margin calls.
ThinkForex does not encourage the use of leverage products with borrowed funds.
ThinkForex does not accept “cash equivalents” as opening collateral (e.g. no securities as deposits).
ThinkForex has chosen not to comply with ASIC’s suggested benchmark on Opening Collateral requirements, which suggest limiting initial funding by credit card to a maximum of $1000.
ThinkForex implements strict controls to ensure that the procedures it adopts when managing exposure to market risk are followed. Further, ThinkForex ensures that the counterparties, with which it transacts to hedge client trades, are of appropriate financial standing. ThinkForex only hedges its positions through prime brokers that hold a minimum capital of 10 million USD (equivalent and are regulated under either ASIC , FCA or a Central Bank in their country of origin.
‘Hedging’ refers to the process where a financial service provider such as ThinkForex reduces or removes its exposure to market risk by entering into a corresponding transaction with another entity. ThinkForex’s main Prime Brokerage accounts are with CitiBank PLC, Saxo Bank Australia and GFT UK.
Furthermore, ThinkForex has enforced trading limits with its prime brokers, which are automatically applied and can only be adjusted by the CEO of ThinkForex, upon request.
Monthly financial reports are prepared to ensure compliance with ThinkForex’s AFSL Conditions and the financial requirements which are contained in ASIC Regulatory Guide 166.
An annual financial audit is also conducted by an ASIC approved auditor.
Stress testing of capital adequacy
The capital requirements and surplus position of ThinkForex is monitored on a daily basis. ThinkForex’s risk exposure that our clients face is calculated by our position keeper and reconciliation software in real time. This software is monitored by risk management staff, 24 hours a day, 5 days a week at all times whilst the foreign exchange markets are operating. Our free margin levels with our hedging counterparties are displayed at all times, showing how much market movement or increase in client position size can be sustained with the current level of funds.
Daily stress testing is conducted and alerts have been established at pre-defined levels to ensure that appropriate remedial action is taken in the event of market movements that are adverse to ThinkForex’s financial position.
This document has been produced by ThinkForex to explain how client money is handled. The purpose is to provide clients with an insight into how client money is reconciled and segregated so that they are better informed to assess the safety of their funds in relation to other financial product providers. All client free margin* is held with National Australian Bank (NAB) and Commonwealth Bank of Australia (CBA), all of which are Australian Authorised Deposit-taking Institutions (ADIs).
The ThinkForex platform automatically emails clients when they fall below their required free margin level. When a client’s free equity falls below 50% of margin requirement, the client’s open positions will be instantly closed out. This helps ensure that the one client’s funds are not used to fund the positions of other clients.
ThinkForex creates an individual trading account for each client, which allows a complete record of transactions to be maintained, so that every client account is monitored and followed. Any default or outstanding payment is immediately followed up, to ensure that the client account stays in balance.
The Compliance Officer will ensure that all unencumbered client funds are placed in segregated trust accounts and invested in accordance with the Australian Client Money Rules, ASIC Regulatory Guide 212 (titled ‘Client money relating to dealing in OTC derivatives’) and ASIC Regulatory Guide 227, where appropriate. We ensure that reconciliations of client monies are conducted and reviewed on a daily basis.
*Free Margin is the amount of funds not in use as margin requirements for holding open positions. For example, If you have equity of $1,000 on your account and the total margin requirements are $250, the free margin amount is $750.
Foreign exchange markets trade continuously. They open at 05:00pm American EST* Sunday evening (Monday morning 11 am AEST) and close at 05:00pm, American EST** on Friday (Saturday morning 11 am AEST). They are open 24 hours during this period.
Prices are continuously streamed during this period. Because foreign exchange is not an exchange-traded product, it is not possible to suspend or halt the streaming of these prices.
For our futures, commodities and index products, ThinkForex will halt client trading and the use of client money in an asset or derivative when a trading halt exists for the underlying asset, or trading in the underlying asset has been suspended through an exchange or otherwise.
* Eastern Standard Time (America)
ThinkForex provides all clients with the option of applying a ‘stop loss’ on any order they place, in order to prevent losses exceeding their desired maximum loss on a position. This does not guarantee that a ‘stop loss’ order will be executed at the desired ‘stop loss’ price.
This email instructs the client to either close some positions or deposit more funds to cover the margin requirement. Furthermore, when a client’s free equity falls below 50% of free initial margin requirement, the client’s open positions will be instantly closed out, reducing the likelihood that clients enter negative equity.