Privacy Policy

I. Introduction

Thank you for visiting the MXCM Trading Platform (hereinafter referred to as "MXCM"). By accessing, entering or using MXCM and its related Application Programming Interfaces (APIs) or mobile applications (collectively referred to as the "Platform" hereinafter), you agree to the relevant provisions and operating methods set out in our Privacy Policy (hereinafter referred to as "this Privacy Policy"). Please be sure to read this Privacy Policy carefully.

 

This Privacy Policy explains how MXCM will use your personal data (as defined below) when you use the services of our digital asset trading platform through our software, application programming interfaces, technologies, products and/or functions (collectively referred to as the "Services" hereinafter).

 

In the course of providing services to you, we need to collect and store your personal information to comply with the legal requirements of the jurisdictions where we operate and improve the quality of our services. Under normal circumstances, we will never disclose customers' personal information to any unrelated third parties, unless otherwise stated below.

 

We may update this Privacy Policy from time to time and notify you by posting the revised version on the Platform.

II. Data We Collect

MXCM collects, processes and stores personal data obtained through your use of the Services or collected with your consent. Such personal data may include the following:

 

Virtual Identity Information: MXCM account/password and MXCM nickname.

Sensitive and Biometric Personal Data: Where permitted by local laws or with your consent, MXCM may also collect sensitive personal data, such as biometric information. For example, verifying your identity by comparing facial scan data extracted from your selfie or video with the photo on your government-issued identification document.

Financial Information: Bank account details, Primary Account Number (PAN) of payment cards, account assets, transaction history, transaction data and/or tax identification number.

Transaction Information: Relevant information about transactions you conduct on the Platform, such as the payee’s name, your name, transaction amount and/or timestamp.

Message Content: Feedback, emails, short messages, app ratings and reviews.

App Usage Behavior: Browser operation records, click logs, search history, installed apps, running apps, crash logs, user-generated content, saved content, mouse movement trajectories, scroll positions, key operations and touch operations.

Device Information: Network operator, brand, software version, model name, manufacturer, system language, operating system version, regional settings, device fingerprint, build number, baseband version, country associated with the SIM card, SIM card serial number, battery status, network information, Open Anonymous Device Identifier (OAID), International Mobile Equipment Identity (IMEI), Globally Unique Identifier (GUID), Media Access Control (MAC) address, Android ID, Service Set Identifier (SSID), Advertising ID, as well as gyroscope/accelerometer data.

Communication Records: Responses to questionnaires and information provided to our customer service team or user research team.

Audio, Electronic, Visual and Similar Information: Such as call recordings and video recordings.

 

We may collect information you provide during the MXCM registration process, whether the registration process is completed, uncompleted or terminated. When providing services to residents of specific jurisdictions, we will collect, store and process your personal information in accordance with the provisions of local data protection laws (such as the General Data Protection Regulation (GDPR) and Data Protection Act).

 

In addition, to comply with applicable anti-money laundering laws and regulations, we may collect the following personal information:

(I) Individual Customers

Email address

Mobile phone number

Full legal name (including aliases and names written in local languages)

Nationality

Passport number or the number of any government-issued identification document

Date of Birth (DOB)

Identification documents (such as passport, driver's license or government-issued ID card)

Residential address

Proof of residence documents

Other personal data or documents required by the compliance team at its discretion

(II) Corporate Customers

Full legal name of the enterprise (including the legal name written in local languages)

Incorporation information

Full legal names of all beneficial owners, directors and legal representatives

Addresses (principal place of business and/or other actual business locations)

Proof of legal existence documents

Business description

Equity ownership ratios of individual/corporate owners

Contact information of owners, responsible persons and senior management (if applicable)

Identification documents of the key individual beneficial owners of the institutional customer entity (such as passport, driver's license or government-issued ID card)

Personal data of the key beneficial owners of the institutional customer entity (please refer to the "Individual Customers" section above for specific personal data to be collected)

Proof of source of funds

Expected amount of Bitcoin or other digital assets to be deposited

III. Right of Access, Correction, Deletion and Other Rights Relating to Your Personal Data

Pursuant to applicable laws, you are entitled to various rights in respect of privacy protection and personal data protection, as described below. You have the right to request access to, correction and deletion of your personal data, and the right to data portability. In certain circumstances, you may also object to our processing of your personal data or request that we restrict the processing of your personal data. Furthermore, after you consent to our processing of your personal data for specific purposes, you may withdraw such consent at any time.

 

If you wish to exercise any of the rights set out below, please contact our Data Protection Officer via email at [e-mail].

 

In some cases, these rights may be restricted. For example, when applicable laws or anti-money laundering compliance requirements oblige us to process your personal data, your relevant rights may not be fully exercisable.

 

Right of Access: You have the right to confirm whether your personal data is being processed, to obtain a copy of your personal data, and to access specific information related to the data processing.

Right of Correction: You may request the correction of your inaccurate personal data and the supplementation of your incomplete personal data. You may also modify your personal data in your account at any time.

Right to Erasure: In certain circumstances, you may request the erasure of your personal data.

Right to Object: Based on your specific situation, you have the right to object to our processing of your personal data. For instance, you have the right to object when we process your personal data based on legitimate interests or for direct marketing purposes.

Right to Restrict Processing: In specific situations where there are valid grounds, you have the right to request that we temporarily restrict the processing of your personal data. However, we may continue to process your personal data for the purpose of defending legal claims or in other circumstances permitted by applicable laws.

Right to Data Portability: In certain circumstances, you may request that we provide you with the personal data you have previously provided to us in a structured, commonly used and machine-readable format. Where technically feasible, you may also request that we transmit your personal data directly to another data controller.

Right to Withdraw Consent: For the processing of personal data that requires your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the legality of data processing conducted based on your prior consent before the withdrawal.

 

Exercising the above rights may affect the form and content of the services we provide to you. In some cases, exercising these rights may result in our inability to continue providing services to you, and therefore we may need to terminate the contract signed with you.

 

We may charge a reasonable fee for processing your request for access to personal data. If we decide to charge a fee, we will provide you with a written cost estimate. Please note that we are not obligated to respond to or process your access request unless you agree to pay such fee.

IV. Methods of Collecting Personal Data

Most of the personal information we collect is directly provided by you. We will collect and process your information in the following circumstances:

 

When you register, log in or access MXCM online, or use any MXCM Services;

When you voluntarily complete any user questionnaire or provide feedback to us via email or other channels;

When you use or browse our website or client terminal, information is collected through Cookies in your browser or software (Cookies refer to small amounts of data sent by a website to a browser and stored on a computer's hard drive);

Other circumstances of independent information collection mentioned in this Policy.

 

We may also obtain your information from public channels or third-party sources (such as our advertising partners and market research partners), for example, to update or supplement other information we have collected about you.

V. Methods of Using Personal Data

We may use your personal data in the following ways:

(I) Compliance with Laws and Regulations

Most of our Services are subject to laws and regulations that require us to collect, use and store your personal data in specific ways. For example, MXCM must identify and verify the identity of customers using our Services to comply with cross-jurisdictional anti-money laundering laws. This includes collecting and storing photos of your identification documents. If you fail to provide personal information as required by law, we may have to close your account.

(II) Enforcement of the Terms of This Policy

We will actively monitor, investigate, prevent and mitigate any potential prohibited or illegal activities, enforce agreements we have signed with third parties, and prevent and verify violations of this Policy. In addition, your use of our Services may incur corresponding fees. We will collect information about your account usage and closely monitor your interactions with our Services. We may use any personal information collected about you for the above purposes.

(III) Detection and Prevention of Fraud and/or Financial Loss

We will process your personal information to help detect, prevent and reduce fraud and abuse targeting our Services, and to protect the security of your account.

(IV) Provision of Services

To provide you with Services, we need to obtain your personal information. When providing identity verification and/or fraud prevention services, third parties (such as identity verification service providers) may also collect your personal information.

(V) Provision of Service Communications

We will send you administrative or account-related information to keep you informed of updates to our Services, notify you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may fail to receive important matters related to your account in a timely manner, which may affect your use of our Services. You cannot opt out of receiving important service communications (such as emails or short messages) sent for legal or security purposes.

(VI) Provision of Customer Service

When you contact us to resolve issues, we will obtain your personal information. Without processing your personal information, we will be unable to respond to your requests or ensure your uninterrupted use of our Services.

(VII) Ensuring Network and Information Security

We will process your personal information to enhance security, verify your identity and access rights to our Services, prevent spam or other malware and security risks, and comply with applicable security laws and regulations. It is crucial to understand how you use our Services in a timely and accurate manner. Without processing your personal information, we may be unable to ensure the security of the Services.

(VIII) Research and Development

We will obtain your personal information to better understand how you use and interact with our Services. In addition, we will use this information to customize and improve service content and interface layout, and to develop new Services. Without processing your personal information, we may be unable to ensure your continuous use of our Services.

(IX) Enhancing Your User Experience

We will obtain your personal information to provide you with a personalized experience and meet your needs. For example, you may allow us to access specific personal information stored by third parties. Without processing your personal information, we may be unable to ensure your continued use of some or all of the Services.

(X) Supporting Corporate Acquisitions, Mergers or Transactions

In the event of corporate acquisitions, mergers or other business transactions, we may obtain your account information and relevant information about your use of our Services. If you do not wish your personal data to be processed for such purposes, you may choose to close your account.

(XI) Conducting Marketing Activities

We may send you marketing communications (such as emails or short messages) to inform you of our events or those of our partners, provide targeted marketing services, or send you promotional offers. Our marketing strategies will be based on your advertising and marketing preferences and implemented within the scope permitted by applicable laws. If you do not wish to receive marketing information from us, please contact our Data Protection Officer via email at [e-mail].

(XII) Other Purposes with Your Consent

With your consent, we may disclose your personal information for any purpose you approve of.

 

Notwithstanding the above provisions, we may also share your personal data with the following individuals or entities in the following circumstances:

 

Affiliates: As a regular part of conducting business and providing services to you, the personal information we collect and process may be transferred among various companies under MXCM.

Third-Party Service Providers: We may engage other companies or individuals to perform some functions on our behalf, such as data analysis, marketing support, payment processing, content delivery, and credit risk assessment and management. These third-party service providers may only access the personal information necessary to perform their functions and shall not use it for other purposes. Furthermore, they must process personal information in accordance with the terms of our contracts and within the scope permitted by applicable data protection laws.

Law Enforcement Authorities: Pursuant to legal provisions or court orders, we may be required to disclose your relevant information or information about our cooperative relationship with you to relevant regulatory authorities, law enforcement agencies and/or other competent authorities. We will disclose your information to law enforcement agencies within the scope stipulated by law. In addition, we may need to share your information to enforce or assert our legal rights or prevent fraud.

Business Transfers: As our business continues to develop, we may acquire or sell other businesses or services. In such transactions, user information is usually one of the transferred business assets, but it must still comply with the commitments in the previous privacy notices (unless the user gives separate consent). In addition, if MXCM or most of its assets are acquired by a third party (though such a situation is less likely), user information will also be part of the transferred assets.

Protecting the Rights and Interests of MXCM and Others: We will disclose account information and other personal information when we believe that such disclosure helps comply with laws or fulfill regulatory obligations, enforce or apply our User Agreement and other agreements, or protect the rights, property or safety of MXCM, users or others. This includes exchanging information with other companies and organizations to prevent fraud and reduce credit risks.

 

MXCM will not provide, sell, lease, share or trade your personal information to any unrelated third parties unless it has obtained your prior consent, or the third party has separately or jointly provided services to you with MXCM (including our affiliates). After the termination of the services, the third party will be prohibited from accessing such information (including all information it was previously entitled to access). MXCM also prohibits any third party from collecting, editing, selling or disseminating your personal information in any way. If any MXCM user is found engaging in the above activities, MXCM reserves the right to immediately terminate the service agreement with such user.

 

If you are not a natural person with full capacity for civil rights and civil conduct, you have no right to use this Service. Therefore, MXCM advises you not to provide us with any personal information.

VI. Information Storage

The information and data we collect about you will be stored on the servers of MXCM and/or its affiliates. Such information and data may be transmitted to countries, regions or locations outside the country where MXCM collects the information and data, and may be accessed, stored and displayed in regions outside the country of origin of the information. By submitting your personal data, you consent to such transmission, storage and/or processing. For more information on the transfer of personal data outside the European Union and information related to users in the European Union, please refer to the "Supplementary Clauses Applicable Only to EU Users" section.

VII. Cross-Border Data Transfer

To support our global operations, MXCM may transfer your personal information to regions outside the European Economic Area (EEA). Such transfers to regions outside the EEA are sometimes referred to as "third-country transfers".

 

We may transfer your personal information to our affiliates, third-party partners and service providers worldwide. When we intend to transfer personal information to a third country or an international organization outside the EEA, MXCM will take appropriate technical, organizational and contractual safeguards (including Standard Contractual Clauses) to ensure that such transfers comply with applicable data protection regulations.

 

For countries and regions outside the EEA that are recognized by the European Commission as providing an adequate level of protection for personal information, we will also transfer information in accordance with the relevant decisions of the European Commission. Such decisions are known as "adequacy decisions".

VIII. Cookies

(I) Installation of Cookies

When you visit the Platform, the Platform uses Google Analytics through Cookies to record the operation of the Platform and measure the effectiveness of online advertisements. Cookies are small amounts of data sent to your browser and stored on your computer's hard drive. Cookies will only be sent to your computer's hard drive when you access the Platform using a computer.

(II) Functions of Cookies

Cookies are often used to record the habits and preferences of visitors when browsing various content on the Platform. The information collected by Cookies is anonymous aggregated statistical data that does not contain personal data and cannot be used to obtain information from your hard drive, email or personal data. However, Cookies can enable the Platform or service providers' systems to recognize your web browser and obtain and remember relevant information.

(III) Disabling of Cookies

Most browsers are set to accept Cookies by default. You can choose to set your browser to reject Cookies or notify you when Cookies are being installed. Please note that if you choose to disable Cookies, you may be unable to activate or use certain functions of the Platform. In addition, if you choose to reject Cookies, you may be unable to log in to or use Platform services or functions that rely on such Cookies. This section applies to any relevant information obtained through Cookies set by MXCM.

IX. Information Security

Your account is protected by security measures. Please properly keep your account and password information. We will ensure that your information is not lost, misused or tampered with by storing backups on other servers and encrypting user passwords.