Last Updated: January 2024

This Privacy and Cookies Policy (the “Policy”) govern the access to and use of all features, services, products, tools etc. (the “Platform”) branded as CREED AND BEAR CAPITAL (the “Creed and Bear Capital”, “we”, “our”, “us”) and refers to the domain https://creedandbearcapital.com/, all documents, data, materials or other information made available on the Platform.

This Policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us and applies to all users (the “User”, “you”, “your”) using the Platform. By using our Platform, registering with us or submitting information to us you consent that you have read and understood our collection, storage, processing, use, transfer and disclosure of your Personal Data in accordance with this Policy.

1. Definitions

“Account”: refers to a personalised access point, established through a registration process, that allows an individual or entity to engage with the Platform provided by us.

“Third Party Service Provider”: A separate third-party website with whom CREED AND BEAR CAPITAL collaborates but does not have any control over, where you utilize your Account and relevant credentials to access their services (the “Third Party Partner Service”.)

“Personal Data”: includes information relating to natural persons who: can be identified or who are identifiable, directly from the information in question, or who can be indirectly identified from that information in combination with other information;

“User”: refers to any natural or legal person accessing and creating an Account on the CREED AND BEAR CAPITAL Platform according to applicable terms and conditions, using any kind of technological devices that allows reading, listening, and/or watching information on the Platform, or interacting with this information in an active or passively way.

“Platform”: refers to the domain “https://creedandbearcapital.com/”, its applications, and its subdomains. Any kind of redirection link to any kind of website and or platform control by Third Party Partner Websites is not covered by this Policy, therefore you agree to check the relevant privacy and cookies policy in place from the relevant Third Party Partner website.

“Cookies”: refers to a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it or otherwise. For further details on cookies, please visit All About Cookies.

2. Purpose of This Policy

2.1 CREED AND BEAR CAPITAL knows and understands how important it is for you to understand how CREED AND BEAR CAPITAL collects, stores, processes, shares, and uses your data. CREED AND BEAR CAPITAL respects and protects the privacy of Users’ data in our Platform.

2.2 The purpose of this Policy is to describe how CREED AND BEAR CAPITAL collects, processes, and manages Users’ data through the Platform to offer CREED AND BEAR CAPITAL Services.

3. Acceptance

3.1 By accessing and using our Platform, you are consenting to, and accepting, the terms of this Policy, the terms and conditions of the Service, and any other supplementing document provided related to the present document. If you do not consent to receiving cookies, this may in some cases preclude you from using the CREED AND BEAR CAPITAL Platform, Services, or negatively affect the display, or function, of the Platform or Service.

3.2 In any case, CREED AND BEAR CAPITAL will not hold any responsibility for any errors or bugs or malfunctions on the Platform regarding the information displayed and/or its functions, caused by you not consenting to receiving cookies.

4. User Login Credential Information

4.1 Users understand and acknowledge that when they access specific Services provided by Third Party Service Providers through the CREED AND BEAR CAPITAL Platform, they shall be subject to the individual privacy policy of each respective Third Party Service Provider. The privacy practices, data collection, processing, and usage of information by the Third Party Service Provider are governed solely by their respective privacy policies. CREED AND BEAR CAPITAL does not have any discretion or control over the privacy practices of the Third Party Service Provider, under any circumstances whatsoever.

4.2 Users grant CREED AND BEAR CAPITAL permission to use their data and information as required to create and maintain an Account on the Platform. This information includes name, email address, contact details, and any other relevant information as specifically detailed on clause 5, required for Account registration and management. CREED AND BEAR CAPITAL may share your Personal Data with third parties, as detailed described in clause 7.

4.3 Users acknowledge that CREED AND BEAR CAPITAL will use the provided Personal Data to generate login credentials, such as username and password, for accessing the Platform. These login credentials will enable Users to access the various Services provided by Third Party Service Provider through the Platform.

5. Personal Information That CREED AND BEAR CAPITAL Collects From Users

5.1 Your Personal Data is collected and stored with us in order to provide, develop, and enhance our Platform including technical infrastructure, security, compliance, fraud prevention, and customer support. CREED AND BEAR CAPITAL is committed to exercising due diligence when dealing with every User and in the course of conducting business, CREED AND BEAR CAPITAL complies with all the applicable laws and regulations, as may be amended and updated from time to time.

5.2 The Personal Data CREED AND BEAR CAPITAL collects from Users are:

5.2.1 Users – Natural Person –

5.2.1.1 Full name.

5.2.1.2 Date of Birth.

5.2.1.3 Email Address.

5.2.1.4 Gender.

5.2.1.5 Residence Address.

5.2.1.6 Nationality.

5.2.1.7 Zip Code.

5.2.1.8 Telephone number.

5.2.1.9 Credit card details.

5.2.1.10 Source of wealth.

5.2.1.11 Occupation.

5.2.1.12 Passport identification number or National identification number.

5.2.1.13 Bank account details, including branch, account name/number, IBAN etc.

5.2.2 Browser Information –

5.2.2.1 IP address.

5.2.2.2 Login information.

5.2.2.3 Browser type and version.

5.2.2.4 Time zone setting.

5.2.2.5 Platform.

5.2.2.6 Operating system.

5.2.2.7 Transaction history.

5.2.2.8 Pages accessed and links clicked.

5.2.2.9 Trading experience information, including your understanding of relevant risks and ability to withstand financial loss.

5.3 We obtain this information in a number of ways through your use of Platform or other dealings with us including through any of our websites, account opening applications, contact forms, telephone, internet chat systems, our practice account sign up forms, webinar sign up forms and information provided in the course of ongoing client service correspondence. We may also collect information about you from third parties either through customer due diligence providers, sanctions screening providers, credit reference agencies, publicly available sources or screened third party data lists.

5.4 We also keep records of your trading behaviour, including a record of suspicious transactions and orders, your preference for certain types of products and services, your financial transactions, the products you trade with us and their performance, historical data about the trades and investments you have made including the amount invested. We will use your information to provide you with products and services, or information about our products and services, and continuously review your ongoing needs once you open an Account with us or subscribe to information resources on our sites or applications (e.g. blogs, newsletters etc.).

5.5 We also collect, use and share statistical or demographic data for many purposes (“Aggregated Data”). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. Where we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with the law and this Policy.

6. Use of Personal Data

6.1. Purposes for which CREED AND BEAR CAPITAL seeks User’s consent: (i) To communicate with the User; (ii) To comply with legal and regulatory compliance ; (iii) To detect and prevent fraud and credit risks; (iv) To provide, troubleshoot, and improve CREED AND BEAR CAPITAL Platform; (v) To enforce our terms in our Terms of Use; (vi)To provide customer services; (vii) To ensure quality control; (viii) To ensure network and information security; (ix) To enhance and personalise User experience; (x) To engage in marketing activities; (xi) For transaction services;

7. Data Transfer

7.1 CREED AND BEAR CAPITAL may share your Personal Data with Third Party Service Providers, including partners, business suppliers, distributors, and subcontractors, when it is necessary for the delivery of services on the Platform, or when there is a legal basis to do so. CREED AND BEAR CAPITAL complies with the applicable data protection laws, industry standards, and only shares information in the following circumstances:

7.1.1 With applicable regulatory bodies of the Commonwealth of Dominica;

7.1.2 With Third Party Service Providers, and KYC/AML service providers for identity verification purposes when the User is in an onboarding process;

7.1.3 With service providers under contracts to operate the business. For instance; cloud Storage, network infrastructure, security, customer support, marketing, and data analytics.

7.2 Each Third Party Service Provider may have its own data transfer clauses, terms of use, and privacy policies governing how your information is handled, processed, and shared. CREED AND BEAR CAPITAL is advising you to consult the respective privacy policies of the Third Party Service Provider for more detailed information. It may include their practices and instructions about how to opt-out of certain options. By using our Platform to access the services of Third Party Service Providers, you acknowledge and agree to adhere to the data transfer clauses and privacy policies of those Third Party Service Providers.

7.3 CREED AND BEAR CAPITAL is not liable for any disparities in eligibility criteria among Third Party Service Providers. Users are encouraged to directly contact the relevant Third Party Service Provider for clarifications on their access policies. User’s access to any Third Party Service Provider through our Platform is contingent upon the User’s compliance with the respective Third Party Service Provider’s applicable terms, conditions, laws and regulations.

8. Protection and Storage of Personal Data

8.1 CREED AND BEAR CAPITAL maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, processing, use, transfer and disclosure of the User’s Personal Data. CREED AND BEAR CAPITAL uses firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.

8.2 Personal Data collected may be stored and processed in your region, and in any other country where CREED AND BEAR CAPITAL or its affiliates, subsidiaries, service providers, Third Party Service Providers have operating facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem.

8.3 CREED AND BEAR CAPITAL cannot ensure the security or privacy of data transmitted via email, phone, or SMS, until such data reaches the domain of our network since CREED AND BEAR CAPITAL has no access to the involved data until it reaches our domain server..

9. Data Retention

9.1 CREED AND BEAR CAPITAL retains Personal Data for as long as it is needed for the purposes for which we collected it. CREED AND BEAR CAPITAL retains data for as long as you have an active CREED AND BEAR CAPITAL Account. Some information can be deleted from the Platform on request, however, unless prohibited by law, CREED AND BEAR CAPITAL may retain either the original or an accurate copy of all data and information received from its Users in an easily accessible format for a period of seven (7) years subsequent to the termination of your association with our Platform.

9.2 CREED AND BEAR CAPITAL takes reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose of providing services on our Platform for which it was processed. In certain circumstances, if required by law and/or law enforcement agencies, we may not destroy any personal records or Personal Data even though the prescribed period for retention shall have elapsed.

9.3 Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to one (1) year from the expiry of the termination of our association with the User.

10. Governing Law and European Data Protection Rights

10.1 This Policy is governed by and shall be construed in accordance with the data protection laws of the Commonwealth of Dominica. Additionally, the highest global standard of data protection, as set forth in the General Data Protection Regulation (“GDPR”), shall also apply to the processing of Personal Data covered by this Policy.

10.2 According to the GDPR, CREED AND BEAR CAPITAL provides privacy notices, in a concise, transparent, intelligible, and easily accessible form, written in clear and plain language, delivered in a timely manner; and provided free of charge.

10.3 If the Users are located in the European Economic Area (EEA), you will have the rights as described below.

10.4 You may request access to and receive information about the Personal Data that CREED AND BEAR CAPITAL maintains about you, update and correct inaccuracies in your Personal Data, restrict or object to the processing of your Personal Data, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Data to another company.

10.5 You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. CREED AND BEAR CAPITAL will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.

10.6. If you are located in the European Economic Area (“EEA”), CREED AND BEAR CAPITAL will comply with applicable General Data Protection Regulation (“GDPR”) law when transferring your Personal Data outside of the EEA.

11. Your Rights Protected Under GDPR

11.1 Under certain circumstances, according to applicable laws and regulations, you have rights under data protection laws in relation to your Personal Data as detailed below:

11.1.1 Request Access: This enables you to receive copies of your Personal Data CREED AND BEAR CAPITAL holds about you and to check that we are lawfully processing it known as “data subject access request”.

11.1.2 Request Erasure: This enables you to request us to delete or remove your Personal Data where there is no good reason for us to continue to process it. Nonetheless, there may be circumstances where CREED AND BEAR CAPITAL may be legally entitled to retain your Personal Data in accordance with the terms of this Policy.

11.1.3 Request to Restrict Processing: This enables you to restrict the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, CREED AND BEAR CAPITAL 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 defence of legal claims. Be aware that restricting your data processing, can lead to limited access to our Platform.

11.1.4 Request to Object Processing – You have the right to object to the processing of your Personal Data where CREED AND BEAR CAPITAL is relying on a legitimate interest (or those of a Third Party Service Provider) 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 CREED AND BEAR CAPITAL is processing your Personal Data for direct marketing purposes.

11.1.5 Request to Transfer: Under your request, CREED AND BEAR CAPITAL will provide you your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated information that you initially provided consent for us to use or where CREED AND BEAR CAPITAL used the information to perform a contract with you. Any request related to Personal Data held by Third Party Service Provider shall be directly addressed to the involved Third Party Partner.

11.1.6 Right to Data Rectification: This gives you the authority to request the correction of your Personal Data that we process or hold. This right ensures that personal data is accurate, up-to-date, and complete. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us. We are then obligated to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by us.

12. Use of Cookies

12.1 Whenever you visit our Platform, CREED AND BEAR CAPITAL will send a Cookie to the device you are using to access our Platform, who may place tracking technologies on your device, browser, or the webpage you are viewing, in order to personalise your experience, understand usage patterns, provide, improve, and secure CREED AND BEAR CAPITAL Platform. Your device automatically stores the Cookie in a file located within your browser allowing us to recognize your device upon future access. Cookies set by our operators are called “First party cookies”. Cookies set by parties other than our platforms are called “Third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website for instance such as advertising, interactive content, and analytics.

12.2 We use Cookies to:

12.2.1 Optimise your trading experience, including remembering your preferences, location, preferred language, browser and other details;

12.2.2 Authenticate your identity for security purposes;

12.2.3 Maintain our website and certain functions available on it;

12.2.4 Analyse and track the use of our Services;

12.2.5 Adjust our platform according to your trading habits and our regulatory requirements.

12.3. CREED AND BEAR CAPITAL uses the following Cookies to operate the Platform

12.3.1 Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use its features, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. Our Platform 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.

12.3.2 Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform.

12.3.3 First-party-cookies are placed on your device directly by the Platform you are visiting.

12.3.4 Third-party cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking Cookies used to identify online behaviour, understand interests, and then customise advertising the User on other websites. Any information obtained from Third-Party Cookies is processed by the respective collaborative partners.

12.3.5 Persistent Cookies encompass all Cookies that remain on your hard drive until you erase them 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.

12.3.6 Google Analytics Cookies to measure our User’s interactions with the content on our Platform. These Cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration, and Platform activity.

12.3.7 Functionality Cookies allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like, or what 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 the transmission of communications on the network or to supply services whatever requested by you. Further, they help us to know which pages are the most and least popular and see how visitors move around the Platform.

12.3.8 Performance Cookies collect information about how you use our Platform, 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 Platform 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.

12.3.9 Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These Cookies can share information with other organisations or advertisers. However, these are Persistent Cookies which are third-party-proven. 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.

12.4 You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences when accessing our website. However, you will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide you with our services on our Platform. In the event you choose to reject certain Cookies, you may still use our Platform though your access to some functionality and areas of our Platform may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies.

13. Modifications

13.1 CREED AND BEAR CAPITAL reserves the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time indicating the date on which the latest changes were published at the top of this page.

13.2 Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. CREED AND BEAR CAPITAL encourages You to regularly visit our Platform to stay informed about any changes to these Policies and the Terms.

13.3 Your continued access to the Platform means that you agree to the updated content and to abide by the updated Policy. The most updated version of this Policy is available at Privacy & Cookies Policy

14. Contact Information

14.1 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 support@creedandbearcapital.com