Privacy Policy

Updated 23 December 2022

1. Introduction

The terms of this Privacy Policy constitute an inseparable part of the Destiny Terms of Use. The terms in this Privacy Policy shall have the same meaning assigned to them in the Terms of Use unless otherwise specified.

This Privacy Policy outlines our practices with respect to collecting, using, and disclosing your information when you use the Services, including your personal data, which includes information that relates to a living individual and can be used to identify that individual (“Personal Data”). This Privacy Policy covers all of our Services and products and all methods by which you may access our Website and/or our Services, including the web and mobile applications.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy.

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, which is outlined in the GDPR Privacy Notice and that constitutes an addendum to this Privacy Policy.

We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. We aim to protect the security and confidentiality of Personal Data about you that we acquire.

2. Information We Collect

To use the Services, you will be required to fill in and provide the following two categories of information: identity information and services information. We do not collect any personally identifiable information about you unless you provide it. Therefore, if you do not want us to obtain any personally identifiable information about you, please do not submit it to us.

A. Identity information

The Company may collect the following identity information about you to provide the Service:

1. name, nationality, gender and date of birth, country of residence, email address, and phone number;
2. a copy of your national identity card and a recent passport/driver’s license photograph;
3. your residential address, including proof of address such as your bank statements or utility bills;
4. bank account information and credit-related Personal Data including bank statements or tax assessments;
5. location data;
6. details of an individual's dealings with us, including telephone records, email and online interactions; and
7. other information as may be provided by you from time to time when you engage in our Services, respond to surveys available on the Services or communicate with us.

B. Service information

The Company may collect the following information that helps us to contact you and provide you with the Services, including but not limited to:

1. information relating to the device you use to access the Services, including the type of device, its operating system, unique device identifier, IMEI and/or IP address used, Cookies and other web technologies;
2. information about how you use the Services, such as browser type, operating system, referring/exit pages, the features of the Services you used or browsed and the time spent on those features, search terms, the links on the Services that you clicked on and related data. We use such information to administer the Services and we analyze (and may engage third parties such as Google Analytics to analyze) such information; and
3. location information derived from your IP address or your mobile device’s GPS coordinates, if you enable location services on your device. We may use location information to improve and personalize the Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

3. Sources of Information

Wherever possible, Company will collect Personal Data and other information directly from you. We will only collect, use and disclose Personal Data with your consent, your deemed consent, or as may be otherwise permitted under other applicable laws. In addition to the Personal Data you provide to us, certain information related to you that is not considered Personal Data under applicable laws may also be collected.

The Company may collect Personal Data and other information from other sources, such as our affiliates, our service providers, or our affiliates’ service providers; public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud or financial crimes. The Company is not responsible for privacy policies and data protection of these other sources, or how they obtain relative information.

If you visit any of the links to third-party websites as are listed on the Platform or any link of any of our third-party partners, you shall agree to and comply with the separate and independent Privacy Policy of such third-party websites. We will not bear any liability for the contents and activities of such websites or the partners.

4. Use Of Your Information

We will use your information that we collect for the following purposes or in the following ways:

1. set up your Destiny Account and provide the Services;
2. maintain records of your transactions, and provide support to your account generally;
3. identify and authenticate your access to the Services;
4. authenticate your identity for the purpose of compliance with regulatory Know Your Customer and Anti-Money Laundering requirements;
5. send you relevant push notifications, which are based on different activities offered by the Services;
6. communicate with you and keep you informed of our latest updates and newsletters.
7. market our Website, Platform, and Services;
8. serve you personalized advertisements when you use the Services;
9. perform research or conduct analytics in order to improve and customize the Services to your needs and interests;
10. support and troubleshoot the Services and respond to your queries;
11. enforce and/or investigate violations of our agreements, policies, procedures, and/or Terms of Use;
12. detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
13. investigate violations and enforce our policies, and as required by law, regulation, or other governmental authority, comply with a subpoena or similar legal process or respond to a government request.

5. Sharing of Information

We do not disclose your Personal Data to any third parties, except to those who require access to the data in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it, including our affiliates, service providers, partners, principals, auditors and other third parties for purposes of maintaining and improving the Services, performing Services on our behalf, advertising campaigns or other activities in connection with the Services.

We may share your Personal Data with governmental and regulatory authorities and entities, either at our own will or legal obligation or under a lawful request, including, but not limited to law enforcement authorities, regulatory agencies, self-regulatory agencies, and other appropriate agencies in connection with suspected or real fraud or other unlawful activities, prevent harm or financial loss. This includes sharing Personal Data in response to subpoenas, warrants, court orders, disclosures or other legal or investigative proceedings.

6. Retention of Information

We are required under applicable laws and regulatory requirements to retain certain information, including, but not limited to, Personal Data of Users, User profiles, identification verification materials, and the information we used to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, account information, account agreements, trade orders, trade confirmations, and other agreements, account statements, and other records.

Such records are generally retained as required by law, rule, or regulation, or for the minimum amount of time necessary to accomplish the purpose for which it was collected.

Should you decide to close your Account, we may retain copies of information about you and any transactions or services in which you may have participated in accordance with applicable law and for a period of time that is consistent with such law, the applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services and products, to assist with investigations, to enforce any of our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.

7. Security of Data

We strive to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Data that is provided to the Company by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers), and access control mechanisms to control access to systems and data. We endeavor to engage service providers that have security and confidentiality policies of such service providers to have access to users’ Personal Data. We instruct our employees to use strict standards of care in handling the personal financial information of users. As a general policy, our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers, as required by applicable law and regulatory requirements law or, pursuant to a regulatory request and/or authority.

Despite our efforts to protect the security of your information, no security system is always effective and we cannot guarantee that our systems will be completely secure. We will take reasonable steps and use technical, administrative, and physical security measures appropriate to the nature of the information and that comply with applicable laws to protect Personal Data and other information against unauthorized access and exfiltration, acquisition, theft, or disclosure. Although we take enhanced steps to safeguard information, given the nature of information security, there is no guarantee that such measures will always be successful. We cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied, or otherwise, that such access will be prevented.

8. User’s Rights

Users have the right to, as per applicable law(s), to::

1. request access to your Personal Data;
2. request correction of yourPersonal Data;
3. request erasure of your Personal Data;
4. object to the processing of your Personal Data;
5. request restriction of processing your Personal Data; and
6. withdraw consent to process your Personal Data (which shall also mean that the Services will no longer be provided to you).

You may request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For Information access, correction, or deletion requests, please contact [email protected] with the subject “Delete Information Request”.

In response to information access, correction, or deletion requests, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such requests. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should your request be repetitive or onerous. If a User fails to fulfill the above responsibilities and causes damage to the information and dignity of another person, the User may be held liable in accordance with relevant laws.

9. Use of Cookies and Other Similar Technologies

We use cookies in order to provide better service, facilitate the use of our Platform, track usage of our Services, collect data, and address certain security issues. When you access our Services, we may send the cookies to your computer or phone. Your computer or phone stores the cookie in a file located inside your web browser. The cookies help us keep track of your visits to our Website and your activity with our Website and Services to understand how you interact with us.

We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein.

We use the following types of cookies:

• Strictly Necessary Cookies allow us to provide basic website functions such as browsing capabilities and secure access.
• Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.
• Performance/Analytics Cookies. These cookies may be set on our website by our advertising and marketing service providers and partners. They are used to track online activities and help us provide relevant advertising, links, or other information about our services and products to users visiting other websites after visiting our website. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website. We also use a tool called Google Analytics to collect information about your use of the Services. Google Analytics collects information such as how often users access the Services, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.
• In addition to cookies, we use pixels to measure our marketing campaigns and to understand how users navigate and process the content on our website and interact with our services.
• We use growth, engagement, and analytic tools of third-party advertising networks such as Google and Facebook. You can learn more about their platforms by clicking here and here. You can learn more about Google’s opt-out feature by clicking here.

10. How to Control Cookies

Your browser is likely set to accept cookies. However, if you would prefer not to receive them, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies (as explained below), it is possible that some areas of our website will not function properly when you view them.

You can control our use of cookies through your internet browser or third-party tools.

11. Advertisements and Advertising Tools

A. Advertisements

We may use third-party advertising technology to serve advertisements when you use the Services. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retarget our Users.

B. Advertising ID and Advertising Identifier

The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising. By downloading or using the Application or the Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have an Advertising ID or Advertising Identifier respectively, we will use other identifiers.

C. How to Control Certain Advertising Technology

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: https://optout.networkadvertising.org or http://optout.aboutads.info You may also control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

Additionally, your mobile device operating system may provide mechanisms that allow users to opt-out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt-out using these mechanisms, consult your device settings.

12. Minors

The Services are not designated for individuals under the age of 18. If you are under 18 years old, you should not download the Application, use the Services, or provide any Personal Data to us. We reserve the right to access and verify any Personal Data collected from you. In the event that we become aware that an individual under the age of 18 has shared any information, we will delete such information within a reasonable time. If you have any reason to believe that an individual under the age of 18 has shared any information with us, please contact us at [email protected].

13. Updates on the Privacy Policy

The Company reserves the right to make changes to this Privacy Policy. You should review our Privacy Policy frequently. If we make material changes to our Privacy Policy, our revised Privacy Policy will be posted on our website and it will either be noted on our website that material changes have been made or we will notify our clients by email. The date of the most recent update to our Privacy Policy will be set forth in this Privacy Policy.

14. How to Contact Us

If you have any general questions regarding the Services or the information that we collect about you and how we use them, or would like to submit a complaint concerning your Personal Data, please contact us at [email protected] with the subject “Privacy Request”, which is the only valid and official email through which we will communicate with you in respect to our Privacy Policy, and we will not bear any liability for your failure to use effective contact information, any act, or omission.