This Privacy and Cookies Policy (“Policy”) governs the access to and use of all parts of the Creed and Bear SPC website (“CNB”, “we”, “our”) and all documents, data, materials or other information made available on the website.

Please read this Privacy and Cookies Policy along with the Terms of Use of CNB, which is duly incorporated into this Policy by reference, and note that by using the CNB website, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Policy. This Policy applies to all visitors, users (“User(s)”, “you”, “your”) and others who access or use our website.

  • PURPOSE OF THIS POLICY

    • We at CNB know and understand how important it is for you to understand how we collect, store, process, share and use your personal data. We respect and protect the privacy of our users’ personal data on our website.
      The purpose of this Policy is to describe how CNB collects, processes and manages users’ personal data through the website, which are developed to offer CNB services.
  • ACCEPTANCE

    • By accessing and using our services, you are consenting and accepting the terms of this Policy. If you do not agree or consent with the details we require with any aspect of this Policy, you may at any time withdraw your consent and discontinue access or use of our services.
  • THE PERSONAL DATA CNB COLLECTS FROM USERS

    • Your Personal data is collected with CNB in order to provide, develop and to enhance our products and services including technical infrastructure, security, compliance, fraud prevention and customer support. We are committed to exercising due diligence when dealing with every User on the website, to ensure compliance with applicable Laws and regulations that are required to prevent the facilitation of money laundering and terrorist financing.
    • The personal data we collect from CNB Users are:
    • Retail Users
      • Full name
      • Date of Birth
      • Email Address
      • Gender
      • Residence Address
      • Nationality
      • Telephone number
      • Employment Status
      • Government issued Identity or Driving License
      • Passport details
    • Corporate Users
      • Company name
      • Country of Incorporation
      • Country of Operation
      • A copy of Certificate of Incorporation
      • Source of Funds Verification documents
      • Ultimate Beneficial Owner (UBO) details
      • A letter of authorization issued to individual performing on behalf of entity
      • Passport copies of all Directors & Shareholders
      • Valid Trade License
      • Memorandum of Association
      • Article of Association
      • Registered Address
      • Audited Financial Statement
    • Browser information
      • IP Address
      • Login information
      • Browser type and version
      • Time zone setting
      • Website
      • Operating System
      • Transaction history
      • Pages accessed and links clicked
      • Public blockchain data
    • Log information
      • Device-specific information
      • Location
      • System activity
      • Uniform Resource Locators [URL]
      • Data collected via Cookies
  • WHY USERS’ PERSONAL DATA IS USED?

    • We may use personal data for the following purposes:
      • To communicate with User
      • To comply with legal and regulatory compliance
      • To detect and prevent frauds and credit risks
      • To provide, troubleshoot and improve CNB Services
      • To enforce our terms in our Term of Use
      • To provide customer services
      • To ensure quality control
      • To ensure network and information security
      • To enhance and personalize User experience
      • To facilitate corporate acquisitions, mergers or transactions
      • To engage in marketing activities
      • For transaction services
  • DATA TRANSFER

    • We may share your personal data with selected third parties, including business suppliers, distributors and subcontractors, when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use and disclose your information in the ways indicated by us in this Policy.
    • We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances:
      • With applicable regulatory bodies of the UAE. In the event of suspicious activities or transactions such as any fraud, tax, money laundering or terrorist financing activities, CNB is obliged to share the User’s personal information with the applicable regulatory bodies.
      • CNB intends to uphold and implement the strictest standards of compliance, security and transparency in its operation, starting with detailed verification of onboarding Users and transaction monitoring Users sending and receiving activity, and protect Users, therefore CNB acquires the User’s information via third party KYC/AML service providers to provide streamlined verification process for individuals and companies with global coverage, configurable verification rules, detailed and case management tools along with Politically Exposed Person (PEP) database screening, financial crime screening, legality of assets verification and due diligence services.
      • We may also share personal data with service providers under contracts to operate the business. For instance:
        • Cloud storage
        • Payment process
        • Transaction Monitoring
        • Network Infrastructure
        • Security
        • Customer Support
        • Marketing
        • Data analytics
        • With our affiliates/ business partners as a general part of conducting business to offer services
        • With financial Institution which we partner to process payments you have authorized
    • Creed & Bear ensures that the service providers and affiliates/business partners who process personal information acknowledge the confidentiality of this information and are committed to protect the User’s right to privacy by complying with all applicable privacy and data protection laws.
  • PROTECTION AND STORAGE OF PERSONAL DATA

    • Creed & Bear maintains physical, technical, administrative and procedural safeguards in connection with the collection, storage and disclosure of User’s personal data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of User’s online sessions.
    • Furthermore, CNB does not ensure the security or privacy of data transmitted via email, phone or SMS, until such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain.
  • DATA RETENTION

    • Creed & Bear shall keep a copy of all data and information it receives from its User in a readily retrievable format for five (5) years after termination of your relationship with our Services.
    • When an investigation into a suspicious User or a suspicious transaction has been initiated, and in the event that said investigation in respect of the User or transaction is pursued further, CNB shall not destroy any relevant records even though the prescribed period for retention by the reporting authority has elapsed, for the reason that we are subjected to certain anti-money laundering laws.
    • Furthermore, information or data collected via technical means such as cookies, web page counters and other analytics tools are kept for a period of up to one year from the expiry of this Privacy and Cookies policy.
  • GENERAL DATA PROTECTIONS REGULATIONS OF EU

    • If you are located in the EEA, CNB will comply with applicable GDPR laws when transferring your personal data outside of the EEA.
    • EU users are advised to read the important information provided below about the transfer of personal data outside of the European Economic Area (EEA).
    • If you are located in the EEA, you will have the rights as described below.
      • Request access - This enables you to receive copies of your personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      • Request erasure - This enables you to request us to delete or remove personal data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we may be legally entitled to retain your personal data.
      • Request to Restrict Processing - This enables you to object to the processing of your personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
      • Request to Object Processing - You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
      • Request to transfer - If you request the Company to provide you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • COOKIE POLICY

    • Cookies are small text files that are placed on your device like computer, mobile or any other device by a website, containing details of your browsing history. Whenever you visit our website, the website sends a cookie to the device you are using to access our website, and your device automatically stores the Cookie in a file located within your website browser, allowing us to recognize your device upon future access.
    • We use the following Cookies to operate our website;
      • Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our website;
      • Persistent Cookies encompasses all Cookies that remain on your hard drive until you erase or your browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary;
      • First-party-cookies are put on your device directly by our website;
      • Third-party-cookies are placed on your device, not by our website, but by a third party like an advertiser or an analytic system. Generally, the Third-Party Cookies consist of tracking Cookies used for identifying online behavior, understanding interests and consequently customizing advertising the User on other websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;
      • Google Analytics Cookies to measure our User’s interactions with the content on our website. These Cookies collect information about your interactions with our website, such as unique visits, repeat visits, session duration and website activity;
      • Facebook Pixel to process information about a User’s activity on our website, such as the website visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on our website;
      • Essential Cookies are known as strictly necessary Cookies for you to browse our website and use the features of it, such as accessing secure areas of our website. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies help to make our website easy to use by providing basic functions such as page navigation, language selections, authorization and filling in forms. Our website will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed;
      • Functionality Cookies allow our website to remember choices you have made in the past like what language you prefer, what region you would like, or what your username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for transmission of communications on the network or to supply services requested by you. Further they help us to know which pages are the most and least popular and see how visitors move around the website;
      • Performance Cookies collect information about how you use our website, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our website functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit; and/or
      • Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an advertisement. These Cookies can share information with other organizations or advertisers. These cookies may be set through the website by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to two (2) years or deleted, if you erase your browser cookie data.
    • You reserve the right to decide whether to accept or reject Cookies from our website. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the website, as they are strictly necessary to provide you with our Services. In the event you choose to reject certain Cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies.
  • MODIFICATIONS

    • We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time. Such updated details shall be indicated at the top of this page. We will review and revise this Policy when there are any material circumstances arisen that may affect our ability to apply this Policy pursuant to the provisions of statutory and law requirements. What constitutes a material change will be determined at our sole discretion.
    • We will inform our Users on all material amendments to this Policy by publishing the updated version of this Policy on our website. When an updated version of the Policy is released, your continued access to the website means that you agree to the updated content and agree to abide by the updated Policy.
  • CONTACT INFORMATION

    • In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns at legal@creedandbear.com.