Last Updated: 07/01/2025
This Privacy Policy (“Policy”) describes how CFD (“CFD,” “we,” “our,” “us”) collects, uses, and discloses personal information about individuals who use our Site (as defined in the Terms of Use), who otherwise interact with us in any manner, including by phone, by email, or otherwise, and/or in the sale of our products (collectively, our “Services”). Additional policies may apply in other contexts and to other relationships you may have with us, for example, if you are an employee or job applicant. By using our Services or otherwise providing personal information to us, you agree to our privacy practices as described in this Policy. This Privacy Policy should be read in conjunction with our Terms of Use, which govern your use of our Services. Capitalized terms used in this Privacy Policy which not explicitly defined in this Privacy Policy, have the meaning as set forth in the Terms of Use.
Please consult the privacy policies of other websites or applications you may interact with through the Site to learn about their privacy practices.
PERSONAL INFORMATION WE COLLECT & WHY WE COLLECT IT
In this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal information does not include information that is publicly available as defined by applicable privacy legislation or is anonymized.
Generally, we collect (or may in the future, collect) the following categories of personal information, which we use for the business or commercial purposes shown.
| Categories of Personal Information | Purposes for Collection |
| Identifiers and personal records, including real name, alias, postal address, email address, telephone number, signature, unique personal identifier, online identifier, IP address, account name, user name, password, or other similar identifiers, insurance policy number, employment information; bank account number, credit card number, debit card number, or other financial information (tokenized and securely processed by our vendor). This category includes information described in Cal. Civ. Code § 1798.80(e).
Commercial information, including records of personal property, products, or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements IP address, browser type, device identifiers, access times, and pages viewed. Geolocation data, inferred from your IP address Professional or employment-related information, such as employer, job title, and similar information Inferences about your preferences and interactions with our Services User Content. Support Requests: When you contact us, we collect any data you submit. |
To communicate with you.
To provide and maintain the Services. To support our operations, and to improve our Services, including through research and analysis. To develop new services that may be of interest to you. To customize or tailor your experience of the Services. For marketing and advertising. To comply with applicable legal and recordkeeping requirements. For security purposes, including to detect and prevent fraud or other potential harms against you and/or us. To send you service-related communications (e.g. reminders, updates). To understand and analyze how users interact with the Service. To enforce our Terms of Use.
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| Audio, electronic, visual, thermal, olfactory, or similar information, including audio/video collected when you interact with us by phone line or videoconferencing | To communicate with you.
To provide and maintain the Service and its features. To support our operations, and to improve our Services, including through research and analysis. To develop new services that may be of interest to you. To customize or tailor your experience of the Services. For marketing and advertising. To comply with applicable legal and recordkeeping requirements. For security purposes, including to detect and prevent fraud or other potential harms against you and/or us. To send you service-related communications (e.g. reminders, updates). To understand and analyze how users interact with the Service. To enforce our Terms of Use.
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We may use personal information, User Content, Account information, and/or metadata, to develop and improve our machine learning models and artificial intelligence systems and related technologies, including through training, validation, and evaluation. This use is subject to applicable data privacy laws.
We may also use and disclose personal information as required by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense, or declaration in a case or before any judicial and/or administrative authority, arbitration, or mediation panel; or for other purposes described in any other privacy notice or with your consent. Additionally, we may use and disclose personal information to third parties in connection with a sale, assignment, merger, reorganization, or other corporate transaction relating to all or part of our business.
SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION
Generally, we collect the categories of personal information described above from the following categories of sources:
- Directly from you
- Through technologies used on our Services (such as cookies, pixels, and other tracking technologies)
- Created by us (e.g., if we create records pertaining to you, provide you with a login or user ID, or otherwise generate information linked to you)
- If you have a business relationship with us, from you or from other companies we do business with, which may include your employer
- Providers that help us to run our business
- Advertising networks, social networks, internet service providers, and data analytics providers
- Government entities
Analytics. We use analytics tools including Google Analytics to analyze how you interact with our website. This software may collect information such as your IP address, location, operating system, access time, duration of visit, and actions you take on our website. Google Analytics is owned and controlled by Google LLC. Data collected by Google is subject to its privacy policy. You may opt-out of having your website activity made available to Google Analytics by installing the Google Analytics browser add-on, available here.
Session Monitoring. Some of the technologies used on our website allow us and our service providers to monitor and analyze how visitors use our website in order to better understand user behavior and improve our Services. When you interact with us online, information related to your browsing behavior may be collected by us and our service providers.
Do Not Track Signals. Our website does not respond to “Do Not Track” signals sent by browsers, mobile devices, or other mechanisms.
COOKIES. When you use the Site, cookies may be stored on your computer or handheld device. Cookies are small text files that may include an anonymous unique identifier, and allows your usage to be tracked. The Site may use cookies for user authentication, tracking your preferences, and other purposes including to potentially avoid repeated entry of usernames or passwords, and the overall functionality of the Site.
The use of cookies is now an industry standard, and you will find them used on most major websites, but you can always choose to disable cookies from being stored on your computer or handheld device by changing your browser settings. Disabling cookies, however, may result in a limited experience of the functionality and services of the Site.
Some of our business partners whose content is incorporated into or linked to from our site may also use cookies. However, we have no access to or control over these cookies.
HOW LONG WE KEEP PERSONAL INFORMATION
We keep the categories of personal information described above for as long as necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, for as long as your account is active to perform our contractual obligations, for our legitimate business interests, or to satisfy another purpose for which we collected the information;
- Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
- The personal information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case) or enforce the Terms of Use or our agreements; or
- We are otherwise required or permitted to keep your personal information by applicable laws or regulations.
Where personal information is collected and used for more than one purpose, we will retain it until the purpose with the latest period expires. You may delete your account at any time, and we will delete your personal information in accordance with applicable laws.
HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose each of the categories of personal information we collect to service providers, other users of the Services, and contractors for the following business purposes:
- Performing services on our behalf related to the operation of our business and/or the Services (e.g., providing communications, technical, analytical, web hosting, data storage, or other services);
- Utilizing User Content as permitted in the Terms of Use;
- Ensuring security and integrity of personal information;
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, non-personalized advertising
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our Services
- Comply with applicable laws and regulations or other legal obligations
- For safety and security
- Detecting, protecting against, or addressing misuse, malicious, deceptive, fraudulent, or illegal activity
- Any other purpose in accordance with the Terms of Use.
YOUR RIGHTS
Depending on your location, you may have rights under privacy laws including:
· Access to the personal information we hold about you;
· Correction of inaccurate personal information;
· Deletion of your personal information;
· Objection to or restriction of data processing.
To exercise any of these rights, contact us at Phone:1-888-398-0003 or Email:
CALIFORNIA PRIVACY RIGHTS
This section supplements the other parts of our Policy and provides disclosures for California residents under the California Consumer Privacy Act (the “CCPA”).
Right to Know. California residents have the right to request more information regarding the following:
- The categories of personal information we have collected about you, including:
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- The categories of sources from which the personal information was collected
- Our business or commercial purposes for collecting, selling, or sharing personal information
- The categories of recipients to which we disclose personal information
- The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information
- The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information
- The specific pieces of personal information we have collected about you.
Right to Request Deletion of Personal Information. California residents have the right to request the deletion of personal information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
Right to Correct Inaccurate Personal Information. If you believe that personal information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct.
We do not use sensitive personal information to infer characteristics about you or for any profiling purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Submitting Requests Relating to Your Personal Information. To exercise your rights under the CCPA, please submit a request through Phone:1-888-398-0003 or Email: customerservice@cfdnyinc.com.
Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
PRIVACY RIGHTS UNDER STATE LAWS
Depending on your state of residency, e.g., Colorado, Connecticut, Delaware, Iowa, Montana, Oregon, Texas, Utah, Virginia, you may have certain rights regarding your personal information under your state’s privacy laws. These rights may include, among others:
- Right to Know / Access: You have the right to request that we disclose what personal information we collect, use, share, or sell about you.
- Right to Correction: You may request that we correct inaccuracies in the personal information we maintain about you.
- Right to Deletion: You may request that we delete certain personal information we have collected from you, subject to exceptions.
- Right to Appeal: If we deny your request, you have the right to appeal our decision.
Note we do not sell your personal information, which makes some rights inapplicable.
To exercise your rights under these laws, please submit a request through Phone:1-888-398-0003 or Email: customerservice@cfdnyinc.com. We will confirm receipt of your request, verify your identity, and respond as required by applicable law. You may be asked to provide certain information so we can verify your identity. If you use an authorized agent to submit a request on your behalf, we may still require you to verify your identity directly.
We do not discriminate against individuals who exercise their privacy rights. We do not have actual knowledge that we sell or share the personal information of individuals under 18 years of age.
We retain personal information as described in the “How Long We Keep Personal Information” section above. We may also retain anonymized or deidentified data, and we commit not to reidentify such data.
EMAIL PREFERENCES
We want to keep in touch with you in ways that you find to be beneficial. If you no longer want to receive our promotional email communications, you can unsubscribe by clicking on the “unsubscribe” link found in our commercial email messages. If you opt-out of our promotional emails, we may still send you email messages related to your Account or any Services you request from us. Unsubscribing from our promotional emails will not affect the level or quality of service we provide to you.
SECURITY OF YOUR PERSONAL INFORMATION
At no cost to you, we take commercially reasonable and appropriate steps to protect personal information from loss, misuse and unauthorized access, disclosure, alteration, or destruction. Please keep in mind, however, that there is no such thing as perfect security, and no internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any username and password you use for our Services.
INTERNATIONAL DATA TRANSFERS
If you are accessing the Service from outside the country where our servers are located, your data may be transferred to and processed in a different jurisdiction. By using the Service, you consent to this transfer.
THIRD PARTY LINKS
Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies.
CHILDREN’S PRIVACY
Our Services are not intended for children, and we do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from a child, we will delete it in accordance with applicable law.
CHANGES TO THIS POLICY
This Privacy Policy may be revised from time to time for any reason. If this Privacy Policy changes, we will provide you with notice of such changes, such as by sending an email (if you have provided that information to us), providing a notice through the Site or updating the date at the top of this Policy. Your continued use of our Services after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.
CONTACT US
If you have questions about our privacy practices, the contents of this Policy, or if you need to access this Policy in an alternative format due to a disability, please contact us at Phone:1-888-398-0003 or Email: customerservice@cfdnyinc.com