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Privacy Policy

Updated - Aug 30, 2022

Privacy Notice

Date last updated: 30th August 2022

This Privacy Notice applies to our website (, mobile app and other software provided on or in connection with our services (collectively, the "Service" or "our Platform").

This Privacy Notice explains how we collect and use the personal data with which you provide us when you: (i) create an account; (ii) subscribe to our Service; (iii) sign up to our newsletter; (iv) contact us to ask for more information; or (vi) use our Service. It also explains the legal basis for processing your personal data; disclosing your personal data; how we keep your personal data safe; your responsibilities in keeping your information up to date; your rights and how we handle any changes to this privacy notice.

  1. Who are we? We are C M M Software LLC ("We" or "CMM"). We are incorporated and registered in UAE, Dubai. We are the controller in respect of your personal data.

  2. How to contact us? If you have any questions about our Privacy Notice or the data we hold on you, or you would like to exercise your data protection rights, you can contact us at

  3. What data do we collect? We may collect the following categories of personal data from you:
    a. information that you provide to us (including your name and email address);
    b. any communications which you may have with us;
    c. information about account transactions on an exchange account connected to your CMM API Manager including but not limited to: account name, account type and public wallet or deposit addresses; information related to account balances, information about account transactions (e.g. deposits, withdrawals and transfers), including amount, date, time, price, cost basis, fees, quantity, sender and recipient; and
    d. technical information such as your IP address, device type, cookie ID, API keys, web beacons (also known as “pixel tags” or “clear GIFs”), browser-type, broad geographic location (e.g. country or city-level location), date/time stamps, session tokens and other technical information. We may also collect information about how your device has interacted with our Service, including the pages accessed and links clicked. Please see our Cookies Notice for further information.

  4. Information collected from third parties. We don't receive any data about you from third parties.

    Please note that when you pay us, you provide your payment information to a third party payments platform, and we do not see your payment details.

    Our Service is not intended for children and we do not knowingly collect data relating to children. As set out in our Terms of Service, our Service may only be accessed if you are 18 or older. If you are the parent or legal guardian of a child under 13 who you believe has provided personal data to us through the Service, please contact our Support Team at

  5. How we will use your data

    We collect your personal data in order to:

    a. provide, maintain and improve our Service;
    b. register your account;
    c. provide you with any customer support;
    d. enhance the safety and security of our Service;
    e. provide you with notices about your account
    f. notify you about new features (we'll only send you direct marketing by email if you've given us prior consent to receive it). If you'd like to stop receiving these messages from us at any time, you can opt out by clicking the "unsubscribe" link in the email or emailing us at;
    g. meet any legal or regulatory obligations which we have, to enforce or apply the Terms of Service or this Privacy Notice or to protect our rights or the rights of any third party e.g. we may provide your personal information to law enforcement agencies for fraud prevention purposes; or
    h. answer any queries you send to us.

    Some of the information that we collect automatically (if you've given us prior consent to receive it) is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Service, and to deliver a better and more personalised services, including enabling us to:

    i. estimate our audience size and better understand usage patterns;
    ii. recognise you when you return to our Service.
    Please see our Cookies Notice for further information.

    Through the use of our Service, we may also receive trading activity data which is anonymised and aggregated within a larger pool of trading data. As noted in term 13 of our Terms of Service, where able, you grant us a non-exclusive, irrevocable, transferable, worldwide licence to store any trading data you input into our Platform and to access, view and manipulate such data and create derived products. None of this data is personally identifiable which means that it cannot be linked to any specific person or account on our Platform.

  6. What legal basis do we rely on?

    We rely on the following legal bases for processing your personal data:

    a. unambiguous consent (for example, to send you newsletters);
    b. processing is necessary to perform our contract with you (for example, to provide you with the Service and respond to your request); and
    c. it is in our legitimate interests (for example, operating and maintaining the website in order to enable you to analyse your trading transactions via our Service).

  7. Consequences of not providing your personal data.

    Your personal data is necessary for us to provide you with the Service or to allow us to respond to your queries. If you do not supply your personal data to us, then we will be unable to do these things for you.

  8. Who will we share your personal data with?

    We may disclose aggregated and anonymised information about our users and information that does not include any personal data, without restriction. We do not sell any personal information. Please see our Terms of Service for further information.
    We share your personal data with:

    a. our third party payment service providers who help us to fulfil any order that you place via our Service (e.g. Paypal);
    b. our third party suppliers who help us maintain the Website and run our business e.g. our hosting provider, (e.g. Amazon Web Services (AWS)), e-mail marketing provider, (e.g. SendGrid), support service provider (e.g. Zendesk), stack monitoring (e.g. Sentry);
    c. (if you have consented) website monitoring and product analytic providers (e.g. LogRocket and Google);
    d. a third party in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets;
    e. credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud or investigate any breach of the Terms of Service and Privacy Notice and any other third parties where required by law.

    Please note that the Service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, these websites have their own privacy notice and we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.

To use our Service, you must use a third-party exchange. Your interactions with any third-party exchanges are governed by the applicable terms of service and privacy notice of that third party.

  1. Storage and data transfers: We may store information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us or our service providers

    Should we make any transfers outside of the EEA, we will take reasonable steps to make sure that any recipients keep your personal data as safe as possible. By allowing CMM to collect information about you, you consent to such transfer and processing of such information. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open and view content faster.

  2. Data retention and storage. We shall keep your personal data for as long as your account is active. We keep some of your personal data for longer if we are required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Terms of Service, even if it is no longer needed to provide the services to you. When we no longer need personal data, we may anonymise it, securely delete and destroy it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time. We really appreciate it if you let us know if your contact details change. You can do that by contacting us at

  3. What are your data protection rights?

    If you are an individuals in the UK or EEA, you have the general right to request from us:

a. access to your personal data;
b. rectification or erasure of your personal data;
c. restriction of processing concerning you or to object to our processing of your personal data; and
d. the right to data portability. If you wish to exercise any of these rights, please contact us by emailing We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You also have the right to complain to the local data protection authority) about the manner in which we process your personal data.
If you reside in the UK, you can contact the UK Information Commissioner's Office here.

  1. Changes to this Privacy Notice

From time to time, we may need to update this Privacy Notice to ensure that it remains up-to-date. If we make significant changes, we will make that clear on our website or by some other means of contact such as email, so that you are able to review the changes before you continue to use our website.
Please refer to the date at the top of the Privacy Notice to make sure that you are looking at the latest version.