Privacy Policy

Last updated: September 10, 2026

This Privacy Policy describes how [COTFX, LLC — insert full registered legal entity name and registered address] ("COTFX", "the Company", "We", "Us" or "Our") collects, uses, stores, and shares information about You when You use the COTFX mobile application (the "Application") and the website cotfx.app (together, the "Service").

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. If You do not agree with this Privacy Policy, please do not use the Service.

Capitalized terms not defined here have the meanings given to them in our Terms and Conditions.

Summary

Information We Collect

Information You Provide to Us

Information Collected Automatically

Information We Do NOT Collect

We do not collect: precise geolocation; contacts or address book data; photos, camera, or microphone data; health or fitness data; browsing history outside the Service; government identifiers; or financial account, brokerage, or trading account information. The Service does not connect to any brokerage account and cannot see Your trades or balances.

How We Use Your Information

We use the information We collect to:

Legal Bases for Processing (EEA/UK Users)

If You are located in the European Economic Area or the United Kingdom, We process Your personal data on the following legal bases:

Service Providers We Share Information With

We share personal information only with service providers who process it on Our behalf, under contractual obligations to protect it and use it only to provide services to Us. Our current service providers include:

If You sign in with Google or X (Twitter), Your use of those sign-in services is also governed by their respective privacy policies.

We may update this list of providers from time to time; material changes will be reflected in an updated version of this Privacy Policy.

Other Circumstances Where We May Disclose Information

We may also disclose personal information:

We do not sell personal information, and We do not "share" personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA). We have not sold or shared personal information in the preceding 12 months. There is no third-party advertising in the Application.

Push Notifications

Push notifications are optional. You will be asked for permission before any notifications are sent, and You can disable them at any time in the Application's notification settings or in Your Device's system settings. Disabling notifications does not affect Your access to the rest of the Service.

Analytics and Tracking

We use first-party analytics to understand how the Service is used. We do not use Your data to track You across apps or websites owned by other companies, and We do not permit third-party ad networks to collect data through the Service. If Our practices ever change in a way that constitutes "tracking" under Apple's App Tracking Transparency framework, We will request Your permission through the required system prompt before doing so.

Data Retention

We retain personal information for as long as Your Account is active or as needed to provide the Service. Specifically:

Locally stored data (such as Your pair watchlist and app settings) remains on Your Device and is removed when You delete the Application.

Account Deletion and Your Choices

You may delete Your Account at any time from within the Application's settings, or by emailing [email protected] from the email address associated with Your Account. Deleting Your Account removes Your personal information from Our systems as described in the Data Retention section above.

You may also:

Security

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit, access controls, and reputable hosted infrastructure. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and We cannot guarantee absolute security. You are responsible for maintaining the security of Your Account credentials.

International Data Transfers

We are based in the United States, and the Service is operated from the United States. Our service providers may store and process information in the United States and other countries. If You access the Service from outside the United States, You understand that Your information will be transferred to and processed in countries that may have data protection laws different from those of Your country. Where required by applicable law (including for transfers of EEA/UK personal data), We rely on appropriate safeguards such as standard contractual clauses implemented by Us or Our service providers.

Your Privacy Rights

EEA, UK, and Similar Jurisdictions

If You are located in the EEA, UK, or another jurisdiction with similar data protection laws, You have the right to: access Your personal data; correct inaccurate data; request erasure; restrict or object to processing; receive Your data in a portable format; and withdraw consent at any time (without affecting prior processing). You also have the right to lodge a complaint with Your local data protection supervisory authority. To exercise these rights, contact Us at [email protected].

California and Other U.S. States

If You are a resident of California or another U.S. state with a comprehensive privacy law, You have the right to: know what personal information We collect, use, and disclose; access and receive a copy of Your personal information; correct inaccurate information; delete Your personal information; and not receive discriminatory treatment for exercising Your rights. Because We do not sell or share personal information as defined by those laws, no opt-out of sale/sharing is necessary; We also do not use or disclose sensitive personal information for purposes requiring a right to limit.

You may exercise these rights by emailing [email protected] or using the account deletion function in the Application. We will verify Your request using the email address associated with Your Account. You may designate an authorized agent to make a request on Your behalf, subject to verification.

Do Not Track and Opt-Out Preference Signals

The Service does not respond to "Do Not Track" browser signals because there is no uniform standard for them. Because We do not sell or share personal information, opt-out preference signals such as Global Privacy Control do not change how We process Your information.

Children's Privacy

The Service is intended for users who are at least 18 years old, and Our Terms and Conditions prohibit use by anyone under 18. We do not knowingly collect personal information from anyone under 18, and in particular do not knowingly collect personal information from children under 13 (or the applicable age of digital consent in Your jurisdiction). If We learn that We have collected personal information from a child, We will delete it promptly. If You believe a child has provided Us personal information, please contact Us at [email protected].

Third-Party Links and Content

The Service may display content from, or contain links to, third-party websites and services (such as news sources or economic calendars). This Privacy Policy does not apply to those third parties, and We are not responsible for their privacy practices. We encourage You to review the privacy policies of any third-party sites You visit.

Market Data Is Not Personal Information

The positioning data, price data, signals, charts, and other market Content displayed in the Service is derived from public and licensed third-party sources and does not contain Your personal information. Your personal information is never included in, or used to generate, the market Content shown to other users.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the "Last updated" date. If a change is material, We will provide additional notice, such as an in-app notice or an email to the address associated with Your Account, at least 30 days before the change takes effect where required. Your continued use of the Service after the effective date of an updated Privacy Policy constitutes Your acceptance of it.

Contact Us

If You have any questions about this Privacy Policy or Our data practices, You can contact us:

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