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Updated: 29 July 2024

Important Information and Who We Are

The Company, listed in the Contact Information below, and its subsidiaries and affiliates ("we", “FXTM Coach”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice.

This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other digital properties, communications, or forms that link or refer to this notice (our "Website") or our apps on Google Play or App Store (our “App”). This notice applies to the personal data collected through our Website and the App, regardless of the country where you are located.

The Website and the App may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website and the App, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with our Website and the App after any such revisions indicates that you accept and consent to them.

Data We May Collect About You

We collect and use different types of data from and about you including:

• Personal data that we could reasonably use to directly or indirectly identify you, such as your name, address, email address, telephone number, username, password, financial information, or other similar identifiers ("personal data").
• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website or App feature.
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
• Non-personal details about your Website, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page; and App interactions.
• If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

How We Collect Data About You

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our Website and the App, enter a competition, promotion, or survey and when you report a problem with our Website or the App.
• Automated technologies or interactions. As you interact with our Website and the App, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies.
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.
• User contributions. You also may provide information for us to publish or display ("post") on public Website areas, the App or transmit to other Website users or third parties (collectively, "User Contributions"). You submit User Contributions for posting and transmission to others at your own risk. We cannot control the actions of any Website and App users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

How We Use Your Personal Data

We use your personal data to offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• Present our Website and the App and provide you with the information that you request from us.
• Meet our obligations and enforce our rights arising from any contracts with you or to comply with other legal requirements.
• Fulfil the purposes for which you provided the data or that were described when it was collected.
• Notify you about changes to our Website, the App, or services.
• Ensure that we present our Website and the App content in the most effective manner for you and for your devices.
• Administer our Website and the App and conduct internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Improve our Website and the App, products or services, marketing, or customer relationships and experiences.
• Protect our Website, the App, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

If you do not want us to use your data in a specific manner, please contact us through our Contact Information.

We may use non-personal data for any business purpose.

Cookies and Automatic Data Collection Technologies

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

• Estimate our audience size and usage patterns.
• Store your preferences so we may customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Certain features of our Website may use flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies and browser cookies use different management tools, and you must manage their settings separately.

Our Website pages and e-mails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Disclosure of Your Personal Data

We may share your personal data with:

• Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
• Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization).
• Affiliates, subsidiaries and third parties to market their products or services to you if you have not opted out of these disclosures.
• To fulfil the purpose for which you provide it.
• For any other purposes that we disclose when you provide the data.
• With your consent.

We may also disclose your personal data to third parties:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal data without restriction.

Consent to Personal Data Transfer

We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. By submitting your personal data or engaging with our Websites and the App, you consent to this transfer, storing, or processing.

Your Personal Data Use Choices

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

• Promotional Offers from the Company. If you do not want us to use your email address/contact information to promote our own products and services, or third parties' products or services, you can opt-out by sending us an email with your request to our Contact Information.
• Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to our Contact Information.
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

Our Website and the App may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your personal data we consider, among others: any statutory or regulatory retention periods, the amount, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, applicable legal requirements etc.

Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by logging into the Website, the App and visiting your account profile page. You may also send us an email our Contact Information to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information's accuracy.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or because other Website users may have copied or stored them.

Data Security

We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.

Where we have given you (or where you have chosen) a password for access to certain parts of our Website and the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Changes to Our Privacy Notice

We will post any changes we may make to our privacy notice on the Website. If the changes materially alter how we use or treat your personal data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website. Please check back frequently to see any updates or changes to our privacy notice.

Contact Information

Please address questions, comments, and requests regarding this privacy notice and our privacy practices to:

Privacy Policy

Company
Exinity Limited

Address
5th Floor, 355 NEX Tower, 
Cybercity Ebene, 
Republic of Mauritius

Contact details
Data Protection Officer
dpo.mu@exinity.com
+44 203 734 10 25