# Privacy and Data

## Trust

### Privacy & Data

ClickOptions is committed to protecting user privacy and handling personal data responsibly. We collect, process, and retain user data only as required to operate the platform, meet regulatory obligations, and improve user experience.

#### **Data We Collect**

* Identity documents (government-issued ID, passport, driver’s license).
* Biometric data (selfie/liveness check).
* Proof of address (utility bill, bank statement, government correspondence).
* Financial data (Source of Funds / Wealth when required).
* Device, browser, IP address, and geolocation.
* Usage data (pages visited, activity logs, trades executed).
* Information from third parties (KYC providers, custodians, sanctions/PEP lists).

#### **Data Retention**

* Identity verification and transaction data are retained for a minimum of **5 years after account closure**, per AML/CTF requirements.
* Marketing preferences are retained until you withdraw consent.
* Other data is kept only as long as necessary for legal or operational purposes.

#### **Analytics & Cookies**

* Analytics tools are used to improve platform performance and user experience.
* Cookies are used for:
  * Authentication and session management.
  * Security and fraud prevention.
  * Personalization and product improvements.
* Users may disable cookies in browser settings, but some features may not function correctly.

#### **Data Sharing**

Your data may be shared with:

* Identity verification providers (e.g., Veriff, SumSub).
* Custodians (e.g., BitGo, Fireblocks, Copper, Cobo, ClearLoop).
* Regulators and law enforcement where legally required.
* Authorized IT, analytics, and hosting service providers.
* Affiliates and referral partners where you provide consent.

#### **User Rights**

Depending on jurisdiction, you may have the right to:

* Access the data we hold about you.
* Correct inaccurate or incomplete information.
* Request deletion of your data (subject to AML/legal retention).
* Restrict or object to certain processing activities.
* Request portability of your data in a usable format.
* Opt-out of marketing communications.

Requests can be made at: **<privacy@clickoptions.ai>**

#### **International Transfers**

* As a global platform, your data may be stored or processed outside your home country.
* Where transfers occur, ClickOptions applies **Standard Contractual Clauses (SCCs)** or equivalent safeguards to protect your data.

#### **Data Protection Practices**

* Encryption of personal data in transit and at rest.
* Strict role-based access control.
* Continuous monitoring, audits, and regular security reviews.
* Contractual safeguards with all third-party providers.

#### **Transparency Commitment**

* A full Privacy Policy is available on the ClickOptions website.
* Users will be notified of material updates to privacy practices.

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