1. Your consent
1.1 You, on the basis of your own free will and your requisite consent, agree to disclose your personal information to us;
1.4 You agree that CKG Group may contact you in connection with the products and services that you may be interested in (unless you have indicated that you do not want to receive such information).
2. Information Collected
2.1 We process personal data about you when you interact with us, our websites, our apps or our services (including API services). This includes:
- your name, email address / username, password and other login/security details (e.g. app passcode, two-factor authentication token seed record, public PGP key), and login records;
- your payment details / bitcoin wallet address;
- your account and portfolio details, such as live and historical orders, trades and positions, and balances;
- your site and account preferences, including site notification, sounds and confirmation dialogs and leaderboard preferences;
- any personal data you submit for ID verification purposes, and your self-reported location plus the geolocation of the IP address you connect from;
- your marketing and other communication preferences, and a record of any consents you have given us;
- information related to the browser or device you use to access our website or apps, as well as data that tells us which features of the website/app are popular, or suffer from issues we need to fix;
- customer service notes and other records.
2.2 We will aim to mark data fields as optional or mandatory when collecting personal data from you via forms. Note, in particular, that to create an account, engage in transactions, and where necessary, prove your identity, the provision of personal data is typically mandatory: if relevant data is not provided, then we will not be able to do these things and provide the services you expect.
2.3 We do not collect fingerprints, facial recognition data, or other biometrics. Where you enable biometric security (such as fingerprint or Face ID login), your biometrics will be handled by your device, not by us.
3. Purposes of Information
3.1We will use your information that we collect for the following purposes or in the following ways:
(a) to provide you with our Services through our Website;
(b) to identify and confirm your identity when you use our Website;
(c) to improve and upgrade the services of the Website (your information and feedback received by us can help us improve the service of the Website, so that we can more effectively respond to your service requests and support needs);
(d) to keep statistics relating to the use of our Website and to be used for data analysis carried out in cooperation with government agencies, public affairs institutions;
(e) to personalize your experience (your information will help us to better respond to your personalized needs);
(f) to facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is expressly for the purpose of completing the transaction you require);
(g) to send e-mail regularly (the email address that you provide for the purpose of processing orders may be used to receive information on and updates to your orders, in addition to newsletters, updates, related products or services information, etc., that we may send to you from time to time)
(h)to meet other purposes as specified in the User Agreement of this Website and all legal means adopted for satisfying such purposes.
3.2 We do not sell, trade, or otherwise transfer information or allow others to collect, use information; however, such information does not involve the following parties and does not include the following information: our affiliates, trusted third parties who help us operate our websites, manage our business, or provide services to you, provided that such parties agree to keep such information confidential; When we believe that information disclosure is appropriate, or it is required by any of the applicable laws, regulations, rules or by any order of courts or other competent authorities, and is necessary for executing the strategy of our Website and ensuring the proper functioning of the Website, or as may be necessary for the related parties to provide services, or for the protection of the rights, property or safety of us or other persons. However, your information will not be provided to other parties for marketing, advertising or other purposes.
4.2 When you visit our Website, we use Google stats via cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer hard drive. Only when you use your computer to access our Website can the cookies be sent to your computer hard drive.
4.3 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website. The information collected by cookies is non-registered and collective statistical data and does not involve personal data.
4.4 Cookies, which enable the Website or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website.
5. Fully-automated decision-making
5.1 As the service documentation on our site and our terms of service explain, our trading platform applies certain automatic processes based on your trading positions and the resources on your account.
For example, most DueDEX instruments are highly leveraged. To keep positions in these instruments open, traders are required to hold a percentage of the value of the position on the exchange, known as the Maintenance Margin percentage. If you cannot fulfil your maintenance requirement, and liquidation is therefore triggered, we will cancel open orders on the current instrument, you will be partially or fully liquidated, and your maintenance margin can be lost. For more on that process, see here and the FAQ here.
5.2 Other significant automated decision-making that uses your personal data may also be employed, to protect accounts and to uphold our terms of service. In particular, if you attempt to log-in from a jurisdiction to which our services are restricted, your account may be automatically locked, and you will be invited to contact customer support to unlock it; as part of this, you may be asked to provide proof of ID and/or location outside a restricted jurisdiction. During an account lockout, you will be unable to view your positions, make any trades, or open/close any orders.
5.3 API usage and behaviour is monitored in order to protect our systems and to uphold our terms of service. Automated decision-making may be employed to manage your account’s API access or rate limit permits based on your API usage and trading behaviour (this may include limiting or preventing access and activity on your account).
6. How long does CKG Group retain data?
6.1 Where we process personal data in connection with performing an agreement with you, we keep the data for 6 years from your last interaction with us.
6.2 Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of that request indefinitely, so that we can continue to respect your request in future.
6.3 Where we process personal data for site security purposes, we retain it for 3 years. Longer retention periods may apply, such as where ongoing access to records continues to be important to our defence of legal claims or where we are required by law to retain information for specific periods.
7. Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send or display marketing without your consent. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, changing your account settings, or by contacting us using the details set out below.
8. Getting in touch with us
If you have any questions or concerns about how we process your data, would like to exercise any rights (e.g. to opt out of direct marketing), you can get in touch with our contact point for privacy queries at firstname.lastname@example.org