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CyberX
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CyberX ONE Privacy Policy

Last Updated: March 3, 2022

Version 1.0

This CyberX ONE Privacy Policy ("Privacy Policy") applies when you access or use our CyberX ONE Service (the "CyberX ONE Service" or the "Service") located at https://www.cyberx.com (the "Site") CyberX ONE, which is operated by Cipher ONE Technology Limited (collectively "we", "our", "us", or "CyberX"). It sets out how we collect, use, disclose and otherwise process your Personal Information in connection with your access to and use the CyberX ONE Service. Please read this Privacy Policy carefully.

This Privacy Policy is only applicable to CyberX ONE Service described on the Site (https://www.cyberx.com). If you are a client of a prime broker business who has separately entered into service agreements with us, please refer to your service agreements and our additional disclosures for more information about how we collect, use, disclose and otherwise process your Personal Information.

"Personal Information" means any information relating to an identified or identifiable natural person, or as otherwise defined under applicable laws. We may update this Privacy Policy to reflect changes in how we process your Personal Information or changes in applicable laws on a regular basis. Any update to this Privacy Policy will be effective upon its posting on our website at https://www.cyberx.com. In addition, we may also notify you to inform you about the changes to this Privacy Policy as required by applicable laws.

1. Personal Information We Collect

We may collect and process Personal Information about you when you provide us this information or automatically from the devices and browsers you use, as described below.

A. Information You Provide Directly

We may collect the following Personal Information that you provide to us.

  • Account Creation. We may collect information when you register an account for with us, such as name, email address, jurisdiction, proof of address, date of birth and business information such as company name, registration number and proof of address, certificate of incorporation, etc.
  • Usage Information . We may collect information related to your interactions with our Service such as trading information and other activities such as name, portfolio information, account information, API, or information about the trade such as the amount traded.
  • Communications with Us . We may collect Personal Information, such as name, email address, or mailing address when you request information about our Service, request customer or technical support or otherwise communicate with us.
  • Surveys . We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
  • Interactive Features . We and others who use our Service may collect Personal Information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

B. Information Collected Automatically

We may collect Personal Information automatically when you use the CyberX ONE Service.

  • Automatic Data Collection . Device information and internet or other electronic network activity information such as your browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and users’ pattern of the use of the website.
  • IP and geographic location . Internet protocol (IP) address and approximate geographic location based on the IP address.
  • Cookies, Pixel Tags/Web Beacons, and Other Technologies . We, as well as third parties that provide content, advertising, or other functionality on our Service, may use cookies, pixel tags, web beacons, and web technologies to automatically collect information through your use of our CyberX ONE Service.
    • Cookies . Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
    • Pixel Tags/Web Beacons . A pixel tag (also known as a web beacon) is a piece of code embedded in our Service that collects information about engagement on our Service. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

C. Information We Collect from Third Parties

  • Information you post on Social Media Platforms . We use social media platforms to recruit new clients and provide instant support. We can collect information you set to be public in your social media accounts or information you communicated with us on the social media platforms from those social media platforms, such as Telegram, Discord, etc.
  • Analytics . We may use technologies and other third-party tools to process analytics information on our Service, such as Google Analytics. For more information, please visit Google Analytics’ Privacy Policy .

2. How We Use Your Personal Information

We use your Personal Information for the following business and commercial purposes:

  • Operationally Necessary. This includes technologies that allow you access to our Service, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance-Related. We may use technologies to assess the performance of our Service, including as part of our analytic practices to help us understand how individuals use our Service;
  • Functionality-Related. We may use technologies that allow us to offer you enhanced functionality when accessing or using our Service. This may include identifying you when you sign into our Service or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party technologies to deliver content, including ads relevant to your interests, on our Service or on third-party websites.

We use your information for a variety of business purposes, including to provide our Service, for administrative purposes, and to market our products and Service.

A. Provide Our Service

We use your information to fulfil our contract with you and provide you with our Service , such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Service;
  • Answering requests for customer or technical support;
  • Communicating with you about your account, activities on our Service, and policy changes;
  • Processing your financial information and other payment methods for products or Service purchased;
  • Processing applications if you apply for a job, we post on our Service; and
  • Allowing you to register for events.

B. Administrative Purpose

We use your information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Service;
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading or enhancing our Service;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Debugging to identify and repair errors with our Service;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Enforcing our agreements and policies; and
  • Complying with our legal obligations.

C. Marketing and Advertising our Products and Service

We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Information for marketing purposes, you may contact us at any time as set forth below.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent . We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.
  • De-identified and Aggregated Information . We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Service, or other analyses we create.

3. How We Share Personal Information

We may share your Personal Information with the following categories of parties for the business purposes described above:

  • With our parent company and affiliated companies.
  • With service providers who process Personal Information on our behalf in order to help us provide our Service.
  • If permitted by and done in accordance with applicable laws, with third parties, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event.

We may also share your Personal Information with third parties, to the extent required by law, or if we are under a duty to disclose your Personal Information where necessary to comply with any legal obligation, establish, exercise or defend our legal rights and/or of third parties.

4. Data Retention

Our retention periods for Personal Information are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected. When Personal Information is no longer needed, we either anonymize the Personal Information (and we may further retain and use the anonymized information) or securely destroy the Personal Information.

CyberX shares your Personal Information globally with the companies within its corporate group to for purposes specified in this Privacy Policy. CyberX may also subcontract the processing or sharing of your Personal Information to third parties located outside your country. When you use our website, we may transfer, store and process your Personal Information within and outside of your country of residence, consistent with this Privacy Policy. The processing of your Personal Information may, therefore, be also subject to laws other than the ones from your country.

We take appropriate steps to ensure that transfer of Personal Information will be done in accordance with applicable laws and, in particular, that contractual, technical and organizational measures will be in place.

5. Security

We maintain (and requires our subcontractors and service providers to maintain) organizational and technical measures designed to protect the security and confidentiality of the Personal Information we process. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes. If we become aware of any security incident, we will act in a timely manner in accordance with applicable laws.

6. Third Party Links

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

7. Your Rights

Applicable data protection laws may give you a number of legal rights in relation to your Personal Information that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places, and these rights are not absolute even where they are recognized under local law. However, you may have the following rights in accordance with applicable laws:

  • Right to access to the Personal Information that we process about you and certain information about our processing practices.
  • Right to rectify or correct your Personal Information if it is inaccurate or incomplete.
  • Right to request that we erase or delete your Personal Information in certain circumstances. But this is a limited right as we may be able to retain certain Personal Information subject to an exception under applicable laws. Once we receive, verify and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
  • Right to object to or restrict our processing of Personal Information about you under certain circumstances. There may be circumstances where you object to, or ask us to restrict our processing of your Personal Information but we are legally entitled to continue processing your Personal Information and/or to refuse that request.
  • Right to lodge a complaint about our processing activities carried out by us before the competent authorities.
  • Right receive a copy of certain Personal Information we process about you.

If you wish to exercise any of the rights set out above, please contact us at the e-mail address in the "Contact Us" section below.

8. Children

Our website is not directed to children under age 16. If we discover that we have inadvertently collected information from children under age 16, we will delete the child’s information from our systems as soon as possible.

9. Use of Cookies

We may use cookies and other tracking technologies to collect data about visits to and interactions with our e-mails and to allow us to keep track of analytics and certain statistical information. Please consult our Cookie Policy for more information.

10. Do-Not-Track Signals and Similar Mechanisms

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our website currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

11. Contact Us

If you have any unresolved privacy concern that we have not addressed satisfactorily in this Privacy Policy or any questions, comments on this Privacy Policy or wish to exercise any of your rights described in this Privacy Policy, please contact us at: [email protected].

12. Your California Privacy Rights

California Consumer Privacy Act. While we have tried to fully describe our data practices elsewhere in this Privacy Policy, this section supplements the description of our information collection and sharing practices elsewhere in this Policy to provide certain disclosures to California residents whose Personal Information CyberX processes pursuant to the California Consumer Privacy Act ("CCPA").

During the preceding 12 months, CyberX has collected, used, and shared the categories of Personal Information described in the section of our Privacy Policy entitled "Information We Collect." For example, depending on how you use our website, this may include your identifiers (e.g., your IP addresses, contact information), commercial information, Internet and other electronic activity information as well as inferences we draw from the other information we collect.

We disclose Personal Information to third parties for various business purposes as state above in this Privacy Policy. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information. While your information is shared in these ways, we do not share information in a manner that we consider a "sale" of Personal Information for purposes of state law.

Please see the "Your Rights" section above for information about your rights to request deletion of Personal Information and to access (or "know") about the Personal Information that we collect, use, and disclose. Your or your authorized agent may exercise your California rights by sending us an email to [email protected]. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Service. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

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