1.   Introduction

1.1.   This Cookies Policy (“Policy”) explains how FYFX Capital Limited (“FYFX”, “we”, “us”) uses cookies and similar technologies (together, “Cookies”) on:

●     www.fundyourfx.io (Website); and

●     app.fundyourfx.io (platform), and related services.

This policy should be read in conjunction with our Privacy Policy and Terms of Service. The definitions used in our Privacy Policy and Terms of Service are incorporated into this Policy by reference. If there is any provision in this Policy that is in conflict with the terms stated in the Privacy Policy and Terms of Service, the terms of the Privacy Policy and Terms of Service shall take precedence in that order.

1.2.   FYFX is the data controller (or equivalent) for your personal data. Our collection, use, storage, retention and disclosure of personal data is governed by this Privacy Policy and, where applicable, our Terms of Service. This Privacy Policy should be read in conjunction with our Terms of Service. By accessing or using the Website or the Services, you confirm that you have read, understood and agree to this Privacy Policy and the Terms of Service.

2.   Regulatory Roles

• EU/UK: FYFX is generally the data controller for personal data processed via cookies we control.
• California/US: FYFX may be a “business” under the CCPA/CPRA, and certain vendors may be service providers/contractors or third parties, depending on how the technology is implemented. (This policy describes cookie choices only. For full CCPA/CPRA disclosures  please refer to our Privacy Policy.
• Hong Kong / Singapore / Australia: FYFX is responsible for complying with applicable privacy laws for our handling of personal data.

3.   What Are Cookies

Cookies are small files or similar identifiers placed on your device. We use them to run and secure our Services, remember your preferences, understand usage and improve performance, and (where enabled) measure campaigns and show relevant advertising.

4.   Cookie Categories We Use

4.1.   Strictly Necessary (Essential) Cookies

These are essential cookies which used to enable core functions (for example: login, navigation, fraud prevention, and basic security). In some instances, the Website will cease to function if the cookies are not present.

EU/UK: these are used because they are strictly necessary to provide the service you request (no consent required under EU/UK cookie rules for strictly necessary cookies).

Can you refuse? Not via our banner (but you can block cookies in your browser. However, this may break site functionality depending on which cookies are disabled).

4.2.   Performance / Analytics Cookies

These cookies are used to understand how visitors use our Services and to improve performance.

EU/UK: we set these only if you consent (unless an exemption applies, which is uncommon).

Can you refuse? Yes

4.3.   Functional Cookies

Functional Cookies are used to remember choices and preferences and provide personalisation.

EU/UK: we set these only if you consent (unless strictly necessary for a feature you request).

Can you refuse? Yes.

4.4.   Advertising / Marketing Cookies

These cookies are used to measure campaigns and (where enabled) show relevant advertising.

EU/UK: we set these only if you consent.

California: these may involve “selling” or “sharing” personal information (including for cross-context behavioral advertising), depending on how they operate; you can opt out (see Clause 6).

Can you refuse? Yes

4.5.   Security and Fraud-Prevention Cookies

We use certain cookies/identifiers to protect accounts, prevent fraud/abuse, and enforce platform rules.

Important: Some security technologies are strictly necessary, while others may be optional depending on implementation. Where consent is legally required for a security-related cookie, we will request it before setting it. Where such cookies are strictly necessary for security or fraud prevention, they are set without consent where permitted by law. Where not strictly necessary, consent will be obtained in accordance with applicable law.

5.   How Consent and Legal Bases Work

For users in the EEA and UK, we follow the following standards for non-essential cookies:

• No non-essential cookies by default: No non-essential cookies are set unless you choose “Accept all” or enable specific categories in our cookie banner or CPC;
• Easy refusal: Our cookie banner provides a clear and equally prominent way to “Reject non-essential cookies” as to “Accept all”, and a “Manage settings” or similar option for granular choices;
• Continued use if you refuse: You can refuse non-essential cookies and continue to use the service (although some features may be limited if you disable Functional Cookies).
• Withdrawal of consent: You can withdraw consent at any time using our CPC. The  changes will apply going forward;
• Renewed consent: If we make material changes that require renewed consent, we will notify you in the manner stated in Clause 11.

Legal Basis Under GDPR/UK GDPR

Where cookies involve the processing of personal data:

• For non-essential cookies (such as most Analytics, Functional, and Advertising/Marketing cookies), our legal basis for setting and reading these cookies, and processing the resulting personal data, is your consent. You can withdraw your consent at any time through the CPC. This will not affect the lawfulness of processing before withdrawal.
• For Strictly Necessary and certain Security and Fraud-Prevention cookies, our legal basis is our legitimate interests in operating, securing, and providing our Services and/or the performance of a contract with you.

For more detail on our legal bases and your rights, please refer to our Privacy Policy.

6.   California (CCPA/CPRA) – Do Not Sell or Share

If you are a California resident:

• Some advertising/marketing cookies may be considered a “sale” or “sharing” of personal information under the CCPA/CPRA.
• You can exercise your right to opt out of sale/sharing through:

○     our CPC;

○     our “Do Not Sell or Share My Personal Information” link (available in the footer of our Website and, where applicable, in the settings or legal section of our platform), and Global Privacy Control (“GPC”) signals (we honor these where applicable).

Where a group company acts as an independent data controller, it is responsible for its own compliance with data protection laws.

Notice at Collection:

We deploy cookies to collect identifiers and online activity information (for example: device/browser identifiers and interaction data). This data will assist us to  operate our Services more efficiently, improve performance/analytics, remember your preferences, and (if enabled) measure and deliver advertising. We generally retain cookie-related information for the periods described in Clause 9 of this Cookies Policy.

For full CCPA/CPRA “notice at collection” details, including the categories of personal information we collect, the sources, purposes, categories of recipients, whether we sell/share personal information, and your rights, please refer to our Privacy Policy and the detailed cookie list in our Cookie Preference Center.

7.   Hong Kong / Singapore / Australia

7.1.   Hong Kong (PDPO)

Where cookies are used for direct marketing purposes, we will obtain your consent where required and provide opt-out/controls through the CPC and other mechanisms described here. You may opt out of direct marketing at any time through the CPC or by contacting us. Access and correction rights apply in accordance with the PDPO and are described further in our Privacy Policy.

7.2.   Singapore (PDPA)

We provide notice of purposes and offer controls over cookies. Necessary cookies support service delivery. Marketing/advertising cookies are only used where appropriate choices/consents have been secured. For users in Singapore, we will obtain your consent before using cookies for marketing/advertising purposes where required by the PDPA. You are entitled to withdraw your consent at any time. Use the CPC to do so or contact us. In absence of unexpected delays beyond our control, we aim to process such requests within thirty (30) days, subject to applicable law.

7.3.   Australia (Privacy Act)

You can manage cookies through our CPC and your browser/device settings. Where consent is required for certain cookie uses (for example, certain advertising technologies), we will request it before we use those technologies. For information on how to access and correct your personal information and how to lodge a complaint under the Australian Privacy Principles please refer to our Privacy Policy.

8.   How to Manage Cookies

You can control cookies through:

8.1.   Cookie Banner / CPC

On your first visit (and periodically thereafter), our cookie banner allows you to:

• Accept all non-essential cookies;
• Reject all non-essential cookies, or
• Manage settings by category.

From the CPC (available in the  footer of the Website), you are able to  change your choices at any time. In some instances, you may also be able to do so through an in-product link such as “Cookie Settings”.

8.2.   Browser settings

Cookies can be blocked or deleted using your browser settings. Keep in mind that if you do, parts of the Website may not function properly. This applies particularly to Strictly Necessary cookies.

8.3.   Mobile Device Settings

Advertising preferences can be partially controlled directly on your device by changing the appropriate settings (for example, limit ad tracking or reset your advertising ID).

8.4.   Third-Party Tools

Some partners provide their own opt-out tools (where applicable). These tools apply to that partner’s use of cookies/identifiers and are in addition to the controls we provide.

8.5.   Do Not Track

We do not currently respond to Do Not Track browser signals, but we honor Global Privacy Control (GPC) signals where applicable as an opt-out of sale/sharing under CCPA/CPRA.

9.   Cookie Retention (General Ranges)

Retention periods for cookies depend on the type of cookie and your settings. As a general guide:

• Strictly Necessary: session to up to 12 months;
• Analytics: up to 24 months;
• Functional: up to 12 months;
• Advertising/Marketing: up to 90 days;
• Security: typically 6–12 months.

These periods represent maximum retention durations and may be shorter depending on user preferences or technical implementation.

10.   International Data Transfers

Cookie-related data may be transferred out of the jurisdiction in which you reside. Where legally required, we use appropriate safeguards (such as Standard Contractual Clauses, and UK approved equivalents where applicable) for cross-border transfers. Further details are available in our Privacy Policy. Where required under applicable law (including PDPO), we will take reasonable steps to ensure that overseas recipients provide comparable protection.

11.   Updates

We may update this Cookies Policy from time to time at our discretion. Changes will be notified to you via email or Dashboard announcement at least seven (7) days before they take effect, except where immediate changes are required for legal, regulatory or platform integrity reasons. When you next use our Website or Dashboard after a change to this Cookies Policy, a pop up window will appear requesting your acceptance of the new Cookies Policy. If you do not agree to the updated Cookies Policy, you may adjust your cookie preferences or discontinue use of the Website and Services. We reserve the absolute right at our sole discretion to terminate your Account and you must cease using the Services.

12.   Accessibility and Complaints

If you need assistance managing cookie controls due to a disability, contact us at legal@fundyourfx.io for alternative methods.

13.   Contact Details

FYFX Capital Limited Unit 2A, 17/F Glenealy Tower, No.1 Glenealy Central, Hong Kong

Email: legal@fundyourfx.io

Website: www.fundyourfx.io

We aim to respond to your request within a reasonable timeframe in accordance with applicable law.