This Privacy Policy (this “Privacy Policy”) describes how CIFD Ltd. BVI and its affiliates (“CIFDAQ”) collect, use, and disclose information about you in connection with your use of the Services and access to the Site, including when you use or interact with the Services or Site, post on any community feature, register for any event or promotional campaign, complete any survey or questionnaire, or otherwise communicate with us through any channel (including but not limited to our social media or contact information provided below). Unless specifically defined in this Privacy Policy, all capitalized terms have the meaning given to them in the Terms of Use. This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy (whether or not affiliated with CIFDAQ). Please note other CIFDAQ Services or Site or Content may also have their own additional Privacy Policy or Terms of Use.
Please read this Privacy Policy carefully so you understand how we handle information about you. We may update this Privacy Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting of the updated terms. In all cases, your continued use of the Services or access to the Site following the posting of any updated Privacy Policy indicates your acceptance of the updated Privacy Policy.
1.1. Information You Share With Us
You may choose to give us information in various situations such as filling out a form, participating in an event or activity, raising support request, giving us feedback, signing up for email alerts, newsletters, etc. The type of information you may choose to give us includes:
a. Identity Information: This includes your name, profile picture or other identifiers.
b. Contact Details: This includes your email and phone number.
c. Personal Communications: This includes your feedback, opinions, communication you send to us for support request, etc.
d. Marketing Communications: This includes your preferences for receiving marketing communications from us and how you interact with our marketing content.
1.2. Information We Collect Automatically
We try our best to limit the information we collect about you automatically; however, we may collect certain types of data when you interact with our Services or Site, including but not limited to:
a. Device Data: This includes data such as browser type, device type, operating system, etc.
b. Blockchain Data: This includes public blockchain data including blockchain addresses and crypto asset transaction information.
c. Aggregate Data: This includes analytics about number of users and types and information such as how many users in the aggregate are using certain protocols with assistance of Services; and location of users such as countries and regions from which users access the Services or the Site.
1.3. Information Collected via Third Parties
We may collect information via third parties to carry out necessary KYC/KYT or to meet AML/CFT requirements. The same have been described more accurately in our AML/CFT Policy.
Our services are expressly for use for people above the age of 18 or majority in their jurisdiction.
3.1. Quality Assurance Purposes: We may use this data to personalise your use of the site or service, improve on our services, provide support, and resolve issues, etc.
3.2. Prevent or Detect Violation of Policies and or Comply with Law: We may use this data to analyse user behaviour to prevent, detect or investigate any conduct that may be in violation of our policies or in order to comply with law, if we have a legal obligation to collect, use or retain information about you or comply with legal requests like subpoenas or requests from government authorities.
3.3. Marketing: We may use this information to analyse the effectiveness of marketing or promotional strategies and market products, services, or campaigns. We may share this information with our sister companies or affiliates for use in our other services. We may also share information with our back servers or service providers. For more information on the kind of data collected by these platforms please refer to their privacy policies.
If you need to update or delete certain data about you or your interaction with the Services, you can contact us.
You also have the choice of collection and use of information. You can choose to not provide certain information but that may affect your use of Services or access to certain features of the Site.
We retain any data collected by us under this Policy for as long as it is necessary to fulfil the relevant purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law such as for tax, accounting, fraud prevention, investigative, and dispute resolution purposes, or to establish or defend a dispute. In some instances, we may anonymise personal information about you such that it can no longer be used to identify you, in which case we can use such information indefinitely without further notice to you.
If you have any questions about this Privacy Policy, please contact us at: Skeleton Bay Lot, Fish Bay, Tortola, VG 1110, British Virgin Islands or at legal@cifdaq.com.
8.1. If You Are a resident of EU, UK, or Switzerland or India
If you are a data subject in the European Economic Area, the United Kingdom, or Switzerland or India, you have certain rights with respect to your personal data pursuant to the General Data Protection Regulation of the European Union (“GDPR”) and Digital Personal Data Protection Act (“DPDP”) similar laws. This section applies to you.
Any reference to “personal information” in this Privacy Policy is equivalent to “personal data” as defined under law. CIFDAQ is the controller of your personal information and is a Data Fiduciary as covered by this Privacy Policy for purposes of GDPR and DPDP. Our address is as follows: 7 Skeleton Bay Lot, Fish Bay, Tortola, VG 1110, British Virgin Islands.
We process your personal data in reliance on the legal bases below. Where the purpose of processing is:
To provide our Services and Site and Improve Them: We process your personal data as necessary to perform the contract under which we provide our Services to you or to allow you to access our Site.
To Comply With The Law and to prevent fraud, and ensure compliance: We process your personal data as necessary to comply with applicable laws and our legal obligations. We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights. We also process your personal data as necessary to comply with our legal obligations.For Marketing Communications; Or For Research And Analytics: We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights.With Your Consent: We process certain of your personal data with your consent. You may withdraw your consent at any time in the manner indicated when you provided consent to the collection of your personal data through your interactions with the Services or the Site.
You may: (i) ask whether we have any personal data about you and request a copy of such personal data; (ii) request that we update or correct inaccuracies in your personal data; (iii) request that we delete your personal data; (iv) request a portable copy of your personal data; (v) request that we restrict the processing of your personal data if such processing is inappropriate; and (vi) object to our processing of your personal data. These rights are subject to applicable law.
If you would like to exercise any of these rights, please contact us (see “Contact Us” section above). To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.
If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, please contact us above. You may also lodge a complaint with your local data protection authority.
If we transfer your personal data outside your local jurisdiction, we will do so in accordance with the terms of this Privacy Policy and applicable data protection law.
8.2. If You Are a resident of California
If you are a California resident, you have certain additional rights with respect to personal information about you under the California Consumer Privacy Act of 2018 (“CCPA”).
We are required to inform you of:
What categories of information we may collect about you, including during the preceding 12 months: See the section “What information do we collect.”
The purposes for which we may use your personal information and the purpose for which we share your personal information: including during the preceding 12 months See the section “How we use information.”
We do not sell any personal information of consumers.
You may exercise these rights yourself or you may designate an authorised agent to make these requests on your behalf. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents. We will not fulfil your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent who does not submit proof that they have been authorized by you to act on their behalf.
If you would like to exercise any of these rights, please contact us at legal@cifdaq.com.