- The type of personal information we collect
- How we collect personal information
- How we use your personal information
- Disclosure of personal information
- Security of your personal information
- Global company
- Additional matters relating to personal information
The type of personal information we collect:
In order to enable us to deal with your inquiries, open and operate an account or to generally provide you with our products and services and comply with laws and regulations, we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) personal information and financial information about you, including but not limited to:
- personal information to establish your identity and background;
- personal information that you provide when you apply for any of our products and services.
How we collect personal information:
We obtain personal information in various ways, including but not limited to:
- when you register an account with Cowrie Exchange through our website;
- through your relationship with us, for example information provided by you when using our products or services, when taking part in customer surveys, competitions and promotions;
- from an analysis of the way you use and manage your account with us, from the transactions you make and from the payments which are made to/from your account;
- when you contact Cowrie Exchange through various methods such as application forms, email, letters and telephone calls. If you contact us or we contact you using telephone, we may monitor or record the phone call for quality assurance, training and security purposes;
- when we obtain any data and information from third parties (e.g. credit reference agencies, regulatory and enforcement agencies, identity verification services) and/or
- from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
Cookies help us give you the best experience of using our site. In this policy we use the term "cookies" to refer to cookies and other similar technologies.
Cookies are small data files that we or companies we work with may place on your computer or other device when you visit our website. They allow us to remember your actions or preferences over time.
- track site usage and browsing behaviour;
- allow you to log-in to your account and navigate through the website;
- monitor the effectiveness of our promotions and advertising; and
- mitigate risk, enhance security and help prevent fraud.
We use both session and persistent cookies. Session cookies are deleted when you close down your browser, while persistent cookies remain on your device until they expire or you delete them. Persistent cookies allow us to remember things about you when you visit our website again.
How we use your personal information
Other than as stated above, we may use your personal information for one or more of the following purposes:
- to verify your account in accordance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations;
- to assess your application for our products and services;
- to manage and maintain your account with us;
- to better manage our business and your relationship with us;
- to improve our products and services and to develop new products and services;
- to notify you about benefits and changes to the features of products and services;
- to administer offers, competitions and promotions;
- to respond to your enquiries and complaints and to generally resolve disputes;
- to update, consolidate and improve the accuracy of our records;
- to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
- to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us;
- to meet the disclosure requirements of any law binding on Cowrie Exchange;
- for audit, compliance and risk management purposes;
- to assess financial and insurance risks;
- to conduct anti-money laundering checks; for crime detection, prevention and prosecution; to comply with any sanction requirements;
- for any other purpose that is required or permitted by any law, regulations, guidelines or relevant regulatory authorities.
Disclosure of personal information
As a part of providing you with our products and services, and for the management and operations of these products and services, and to comply with legal and regulatory requirements, we may be required or need to disclose information about you and your account with us to the following third parties:
- companies and organisations that act as our agents, affiliates and/or professional advisers;
- companies and organisations that assist us in processing or otherwise fulfilling transactions that you have requested;
- law enforcement, regulatory and governmental agencies;
- your advisers (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;
- any other person notified by you as authorised to give instructions or to use the accounts, facilities, products or services on your behalf.
The aforementioned third parties may in some instances be located outside of your country.
We will otherwise treat your personal information as private and confidential and will not disclose your information to anyone outside Cowrie Exchange except:
- where you have given permission;
- where we are required or permitted to do so by law;
- where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Cowrie Exchange;
- where we may transfer rights and obligations pursuant to our agreement with you;
- where we are required to meet our obligations to any relevant regulatory authority (whether in or outside your country).
Security of your personal information
Cowrie Exchange places great importance on ensuring the security of your personal information. We regularly review and implement up-to-date technical and organisational security measures when processing your personal information. Employees of Cowrie Exchange are trained to handle the personal information securely and with utmost respect, failing which they may be subject to disciplinary action.
The personal information we collect from you may be transferred to, stored and processed outside of the jurisdiction in which you reside, and the laws of those countries may differ from the laws applicable in your own country. For example, information collected in the European Economic Area (EEA) may be transferred to, stored and processed at a destination(s) outside of the EEA. Any processing of such information will be undertaken by our staff, or the staff of our third-party service providers, whose roles will include verifying your identity, processing payment details, and providing customer support. By submitting your personal data, you agree to the transfer, storing or processing of it outside of your jurisdiction.
Additional matters relating to personal information
Retention of personal information
Incomplete personal information
Where indicated (for example in application forms or account opening forms), it is obligatory to provide your personal information to us to enable us to process your application for our products or services. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide you with our products or services.
Your right to access and update your personal information
You have a right to access your personal information. Please contact customer support if you wish to have access to your personal information. Cowrie Exchange will take steps to verify your identity before fulfilling your request.
If there are any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal data. Cowrie Exchange may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
Contacting Cowrie Exchange in relation to personal information