개인정보 보호정책

Introduction

We recognize the importance of safeguarding your personal information and respecting your privacy. We understand that you value discretion and expect your data to be handled with care. That’s why we are fully committed to protecting the privacy of every user (“you” or “user”) of our services.

This Privacy Policy describes how we collect, use, and disclose your personal information when you access or interact with our websites, applications, and any other digital platforms through which we deliver our services (collectively referred to as the “Sevices”).

This Policy forms an integral part of our Service Agreement and is incorporated into it by reference.

We strongly encourage you to read this Privacy Policy thoroughly and use it to make informed choices about your interactions with us. By using our Services, you acknowledge and agree to the terms outlined in this Privacy Policy. Continued use of the Services following any updates constitutes your acceptance of the revised Policy.

Data usage

We may collect, use, store and transfer different kinds of personal data about you and for different purposes. For your use, we made the table with data categories, purposes of their use, and lawful bases for processing.

We process the aforementioned data in compliance with the applicable laws and regulations as amended from time to time in order to:

• Be able to perform our contractual obligations towards the Clients and offer them the best possible service.
• Provide our Services efficiently.
• Comply with our legal obligations, including, inter alia, fraud prevention, anti-money laundering, and terrorist financing laws, regulations, and recommendations of FATF.
• Protect our legitimate interests and your vital interests.

Personal data is processed based on the following legal bases:

• Compliance with applicable laws and regulations.
• Performance of contractual obligations towards the Clients.
• Safeguarding our legitimate interests and your interests and fundamental rights do not override those interests.
• On the basis of the Client’s consent.

Please note that applicable laws and regulations require us to store some categories of data after termination of the Service Agreement or deletion of your account. More details are provided in the account deletion section hereof.

Leaderboards

By using the platform, you acknowledge and agree to participate in the leaderboard system and share your trading strategies and performance results. You grant us permission to display your personal data — including your name, experience points, winning amounts, and related statistics — as part of the leaderboard available on the platform.

You also authorize us to generate trading signals based on your activities and to share generalised information derived from your trades. If you appear on the leaderboard, you agree that other users may view and replicate your successful trades.

In line with data minimisation and purpose limitation principles, the personal data processed for this purpose is strictly limited to:

• Profile Data:

  Your name (or User ID if the name is not available), country flag icon, optional profile photo, leaderboard rank, a note identifying your own position (e.g., “you”), online status, experience points, and total winnings.

• Transaction Data:

  ROI (return on investment) percentage calculated over the past 7 days, and the asset, trade direction, and trade duration (to enable copying).

  Note: The actual amount of your trades is never made public.

Only the ROI metric — representing the percentage of successful trades relative to total trades — is used to determine your placement on the leaderboard.

Processing of this data includes: collection, recording, organisation, structuring, storage, adaptation or modification, retrieval, usage, disclosure, transfer (including cross-border when required), alignment or combination, restriction, erasure, and destruction.

Cookies and other tracking technologies

We, along with our trusted partners, use cookies and similar tracking technologies in connection with our services — including when you visit our website or access any part of our platform.

A cookie is a small data file placed on your device while browsing a website. Cookies serve various useful purposes, such as improving your browsing experience, enabling key features, remembering your preferences, and making your interaction with our Services faster and smoother.

Cookies also help us display advertisements that are more relevant to your interests and allow us to collect statistical data about how you use our Services.

Our website uses the following categories of cookies:

• a) Session Cookies These cookies are stored temporarily during your browsing session. They enable the website to function properly and are automatically deleted once you close your browser.
• b) Persistent Cookies These cookies remain on your device for a set period. They allow us to recognize you on return visits and remember your preferences (such as language settings or login information).
• c) Third-Party Cookies These are set by external services that run content or analytics on our site — for example, cookies from analytics providers that help us understand how users interact with our website.

Although cookies do not contain information that directly identifies you, we may link data collected through cookies to the personal information we store about you.

You can remove or disable cookies at any time via your device or browser settings. However, please note that doing so may affect the functionality of certain features and limit your experience on our platform.

With whom we share the information we collect

We do not rent, sell, or share your personal or corporate information with third parties, except as specifically described in this Privacy Policy.

We may share your Personal Information with:

1.Affiliates and Subsidiaries

We may transfer or disclose your information to our subsidiaries or other affiliated entities as part of normal business operations and service provision.

2. Trusted Third-Party Providers

We may also disclose your Personal Information to reliable third-party service providers and partners for the following purposes:

• (i) To authenticate your identity and verify account details.
• (ii) To store, process, or manage data on our behalf (e.g., cloud service providers).
• (iii) To support, deliver, and improve our Services.
• (iv) To conduct research, diagnostics, or analytics related to platform performance.
• (v) To communicate promotional or informational content, in accordance with our Marketing Policy.

3. Legal and Compliance Disclosures

We may disclose your Personal Information if we have a good faith belief that such disclosure is reasonably necessary to:

• (i) Comply with applicable laws, regulations, legal proceedings, or governmental requests.
• (ii) Enforce our policies or agreements, including investigating potential violations.
• (iii) Prevent, detect, or respond to fraud, illegal activity, security threats, or misuse of our Services.
• (iv) Establish or exercise our legal rights or defend against legal claims.
• (v) Protect the rights, property, or safety of the Company, our users, yourself, or others.

Other Legitimate Business Purposes

Your information may also be shared in connection with:

• Displaying advertisements while using our Services.
• Conducting research and anonymous analytics to improve and personalize your experience.
• Providing technical support and responding to user inquiries.
• Investigating policy violations or addressing legal requirements.
• Monitoring and preventing fraudulent, deceptive, or illegal activities, including money laundering and cheating.
• Enforcing intellectual property rights and other legal protections.

Any third party with whom we share your information is obligated to uphold standards of data protection equivalent to those outlined in this Privacy Policy.

Third-party collection of information

This Privacy Policy applies solely to the information we collect and manage directly. If you choose to share your information with third parties — for example, by clicking on a link to another website or application via our Services — please be aware that different privacy practices may apply.

Third-party websites, apps, or services accessed through our platform may have their own privacy policies and terms of use. We strongly encourage you to review those documents carefully before disclosing any personal information or engaging with those services. The presence of a link to a third-party resource does not imply our endorsement or recommendation.

Please note that such third-party content may include material or services that are illegal, offensive, or otherwise inappropriate for some users. By using those external websites or applications, you acknowledge and accept any associated risks and agree that your interaction with them is entirely at your own discretion.

We disclaim any responsibility or liability for:

• The content, policies, or practices of third-party websites or services.
• Any products, services, or representations made by third parties.
• The security or handling of your data once it is transferred to or collected by third-party platforms.

This Privacy Policy does not extend to your activities on such external websites or services.

We use a tool called Google Analytics to better understand how users interact with our Services. Google Analytics collects anonymized data, such as how often users visit our site, which pages they access, and other aggregated usage metrics.

This tool collects your IP address on the date of your visit, but not your name or any personally identifiable information. We do not combine Google Analytics data with any information that could identify you personally.

Google's ability to use and share this data is governed by the Google Analytics Terms of Use and the Google Privacy Policy. We use this information strictly for internal purposes, including improving the functionality and usability of our Services.

Advertisements

We may employ advertising technologies to deliver ads — including interest-based and targeted advertisements — when you access or use our Services. These technologies help tailor ad content to better align with your preferences and online behavior.

To enhance the effectiveness of our advertising efforts, we may also engage third-party partners and share with them non-personal information. These partners assist us in measuring the performance of our ad campaigns and in retargeting users who have previously interacted with our Services.

Opting Out of Targeted Advertising

You have the option to opt out of many third-party advertising networks, including those operated by members of the:

• Network Advertising Initiative (NAI)
• Digital Advertising Alliance (DAA)

For more information about how these organizations collect and use data — and to learn how to opt out of targeted advertising — please visit:

• www.networkadvertising.org/optout_nonppii.asp
• www.aboutads.info/choices

Please note that opting out does not mean you will stop seeing ads altogether — but the ads you see may be less relevant to your interests.

Personal Data Deletion and Rectification Requests

You have the right to request the correction of inaccurate personal data at any time. You may also request the deletion of your personal data (excluding transaction history and other information we are legally required to retain). Requests can be sent in free form (e.g., in the body of an email or as a scanned letter) and must include your full name and contact details for faster processing. We reserve the right to deny requests if we are not satisfied with your identity verification. By default, we delete personal data when it is no longer required for legitimate processing purposes or when storage is no longer necessary under applicable legal obligations. Unless instructed otherwise, we retain collected data for as long as needed to provide our Services and to fulfill legal obligations (up to 7 years), resolve disputes, and enforce our agreements. We may correct, supplement, or delete inaccurate or incomplete data at our discretion.

Safeguarding and Transferring Your Information

We implement industry-standard security measures to protect the integrity and confidentiality of your information. While we make every effort to secure our Services, we cannot guarantee absolute protection against unauthorized access and disclaim liability for third-party misuse. If you believe your privacy has been compromised or our Services have been misused, please contact us.

Marketing

We may use your personal information — such as your name, email address, and phone number — either directly or via authorized third-party partners (“Marketing Affiliates”) to provide you with promotional materials related to our Services or those of our affiliates. You may opt out of receiving marketing communications at any time by sending a blank email with the word "remove" in the subject line. Upon receiving your request, we will remove your contact from our distribution lists. Please note that you may need to unsubscribe separately from any communications sent directly by our Marketing Affiliates. Even after unsubscribing, you may still receive service-related notifications. By accessing or using our Services, you acknowledge and agree that we may share your personal data with trusted partners for direct marketing purposes.

Corporate Transactions

In the event of a corporate transaction (e.g., merger, acquisition, or restructuring), your personal data may be transferred to the acquiring or successor entity, which will assume the responsibilities outlined in this Privacy Policy.

Account Deletion and Recovery

You may delete your account using the in-app interface on Android or iOS. Alternatively, send a blank email with the subject "delete account". Please note that, even after deletion, we may retain certain data (such as transaction records) as required by law to prevent fraud and maintain platform security. In rare cases, we may contact you post-deletion if legally obligated (e.g., in the event of a dispute). Once your account is deleted, we will cease to use your data for purposes not specified in this Policy — including marketing. To request account restoration, send a blank email with the subject "restore account". Some accounts may not be restorable depending on the reason for deletion or the time elapsed.

Updates or Amendments to This Privacy Policy

We may update this Privacy Policy at our discretion. The latest version will always be available on our website. We recommend reviewing it regularly to stay informed about how your data is managed.