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Privacy Policy
Security and Information Disclosure
Last updated: April 4, 2022
COF ("We") respect your right to privacy. This Privacy Policy ("Policy") applies to personal information we obtain through this website and any other related websites and applications. This Policy does not apply to websites operated by other organizations and third parties. This Policy also applies to personal information that we obtain when you use our services or deal with us by phone, email or otherwise. This policy is intended to inform you of the types of information we collect, with whom we share it, what it is used for, how we keep it secure, and what constitutes your data privacy rights.
If you have any questions or concerns about our use of your personal information, please contact us by sending an email to [email protected].

* What personal information does COF collect and why?

The personal information we collect is broadly divided into the following categories∶

Information you voluntarily provide

You must provide us with your identity, contact information and financial data by filling out a form or by mail, phone, email or other contact. This includes personal information that you provide when∶

  • Apply for our products or services

  • Open an account through our website

  • Subscribe to services or publications of COF or related third parties

  • Request a marketing message sent to you

  • Participate in contests, promotions or questionnaires

  • Provide feedback to us

In addition to the above, some parts of our website may require you to provide personal information on a voluntary basis (e.g., in order to subscribe to marketing newsletters and/or submit inquiries). The personal information you are required to provide and the reasons for providing it will be made clear to you when we ask you to provide it.

The information we obtain automatically

When you visit our website, we may automatically obtain certain information from your device. This information may be considered personal information in some countries in accordance with applicable data protection laws.

Specifically, the information we obtain automatically may include your IP location, device type, unique device identifier, browser type, approximate geographic location (such as country or city location), and other technical information. We may also obtain information about how your device communicates with our website and emails, including the pages visited and the links clicked.

We collect this information to better understand our website visitors, where they come from and what content is of interest to them on our website. This information is used for internal analysis and to improve the quality and relevance of the site for our visitors.

Information we obtain through third parties or public sources

Sometimes we may obtain your personal information from third party sources, but only if those third parties have obtained your consent or are permitted or required by law to disclose your personal information to us.

We use the information we receive from third parties to enhance the services we provide to you, for example by providing content related to our services or topics of interest to you.

* Who does COF share my personal information with?

We may disclose your personal information to the following types of recipients∶

  • Our group companies, third party service providers and partners who provide data processing services (such as supporting the delivery of the website, providing functionality or helping to enhance the security of our website) or who process personal information for the purposes described in this Privacy Policy or who inform you when we obtain your personal information.

  • (i) under applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect the vital interests of you or any other person, to any competent law enforcement agency, regulatory, governmental body, court or other third party that we believe is necessary for disclosure.

  • Any prospective buyer (and its agents and advisors) of a proposed purchase, merger or acquisition of our business, provided that we inform the buyer that your personal information must be used only for the purposes described in this Privacy Policy.

  • Any other person to whom you have consented for disclosure.

* Provisions for handling personal information

The lawful basis for our acquisition and use of such personal information will depend on the personal information in question and the circumstances in which we acquire it.

However, we will generally only obtain your personal information with your consent and when we need that information to perform a contract with you. In some cases, we may be legally obligated to obtain personal information from you, or may need personal information to protect important interests.

If we require you to provide personal information to comply with a legal requirement or to fulfil a contract with you, we will clearly state and advise at the relevant time whether we are compelling you to provide your personal information (and what the consequences may be if you do not provide it).

If you have questions about our lawful basis for obtaining and using your personal information or need to know more, please contact us by sending an email to [email protected].

* The purposes for which we use your personal information

Services for you as a customer

Type of information: identity, contact information, country identification codes, sociodemographic, transactions, finances, contracts, document data, communications with you.

  • Set up an account and provide access to your trading account

  • Offer our products and services

  • Assist you with withdrawals, deposits and transfers

  • Respond to your inquiries via online inquiry, email and phone

Legal basis

(for processing personal information)

Fulfillment of the contract with you (the customer)

Manage our operations and business

Type of information: transactional, financial, contractual, technical, location, usage data

Purpose

Managing our risk and financial position

Stress testing for our systems and controls

Review and enhance our processes

Conduct a review

Collecting and recovering money owed to us

Testing new products and services

Build relationships with other companies that provide services to you

Legal basis

(for processing personal information)

Fulfillment of the contract with you (the customer)

Legal Obligations

Execute our business with efficiency

Innovate and develop new products to suit customer needs

Manage risk, prevent financial crime, and respond to regulatory and legal requirements

Type of information: transaction, financial, identity

Purpose

Detecting, investigating, reporting and seeking to prevent financial crimes

Managing risk for us and our clients

Compliance with applicable laws and regulations

Responding to complaints and seeking resolution

Purpose

Assess your personal data before and during the relationship with you

Submit information to regulators for investigative purposes when necessary

Legal basis

(for processing personal information)

Public interest under the law

Legal Obligations

Preventing fraud, money laundering, financial crime and safeguarding the public interest

* How does COF keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information we obtain and process about you. The measures we use are designed to provide a level of security that is commensurate with the risks arising from the processing of your personal information. Specifically, we∶

  • Store personal information in a secure device and store the information electronically on a secure server.

  • Use encrypted transmission links whenever possible.

  • Use other protective measures such as firewalls, authentication systems (e.g., passwords), and access control mechanisms to control unauthorized access to systems and data.

  • Regularly review our information collection, storage and processing, including physical security measures, to prevent unauthorized access to our systems.

  • Restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are under strict contractual obligations of confidentiality. COF may discipline or terminate individuals who obtain information in bad faith but are not entitled to access that information.

* International Data Transfer

For the purposes described in this Privacy Policy, we may transfer your personal information to third parties located in third countries for further processing, subject to certain conditions. In these cases, we will ensure that your privacy is adequately protected by appropriate technical, organizational, contractual or other lawful means, including data transfer agreements for the transfer of personal information between our group companies, which will require all group companies to protect the personal information they process. We have implemented similar appropriate protection measures with our third party service providers and partners and can provide more details upon request.

* Data saving

Your personal information will only be retained for as long as necessary to carry out the purposes described in this Privacy Policy (unless a longer retention period is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may retain your personal information in an anonymous form only if we have a legitimate interest and benefit, and that information will cease to refer to you indefinitely.

* Automated Decision Making

In some cases, our use of your personal information may result in automated decisions (including analysis) that have legal implications for you or other similarly significant implications.

Automated decision making representatives automatically make decisions about you based on computer calculations (software algorithms) with no human review.

When you open an account, we will use the information you provide to check the suitability of the products or services offered for you and to make automated decisions. For example, we may use information about your financial situation or socio-demographic information to assess your suitability and to understand the risks involved in trading our products.

When we make an automated decision about you, you have the right to disagree with that decision, state your opinion, and request a manual review of that decision. You can exercise this right through this dedicated page. Please note that you may need to prove your identity in order for us to provide you with the service.

* Your data protection rights

Under certain conditions, the data protection law gives individuals the right to: access, rectify, withdraw consent, delete, restrict, transfer and object to the processing of their personal information. If you believe that your personal information has not been processed in accordance with the law, you have the right to file a complaint with the relevant data protection authority. More information about your rights is provided below:

  • Right to a copy of your personal information. You have the right to receive a copy of the personal information we hold about you.

  • Right to Correction. You may request that we correct any personal information that is incorrect and/or complete any incomplete information. We will correct the records and notify any third party to whom such personal information has been transmitted (as described above).

  • Right to data portability. You may ask us to provide you with a copy of all your personal information, which we will then transfer to another data controller of your choice.

  • The right to withdraw from marketing communications.You can exercise this right by clicking on "unsubscribe" or "opt-out" in the marketing emails we send you.Or contact us at Contact COF .

  • Right to withdraw consent. You may revoke your consent to the processing of your personal information at any time. Such revocation will not affect the lawfulness of the processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain features of the service that are important for the processing of your personal information.

  • The right to object to processing. You can ask us to stop processing your personal information. Please note that you may not be able to benefit from certain features of the service that are important to the processing of your personal information.

  • Right to delete. You may request that we delete your personal information and we will comply with the request unless there are legal reasons for not doing so.

* Update this Privacy Policy

We may update this policy from time to time to respond to changing legislation, technology or business developments. When we update our policy, we will take appropriate steps to notify you of the significance of the changes we make.

You can see when this policy was last updated by looking at the "last updated" date at the top of this policy.

* How to contact us

For any questions, comments and requests regarding your information or privacy policy, please contact us by sending an email to [email protected].

Risk Warning∶Our services include products traded on margin, which carry the risk of loss in excess of your deposited funds and may not be suitable for all investors. Please ensure that you fully understand the risks involved.

 

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