Koi’s Policy applies to current and former Koi clients and any other users of the Koi Trading Site. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.
How and Why We Gather Information
When you apply to create an account on a Koi Trading Site, you will be asked to provide information such as your or your entity’s full legal name, address and date of birth/formation, along with other information that is required to verify your or your entity’s identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences and/or fulfill our ongoing legal and regulatory requirements.
Types of Information We Collect
The information we collect and maintain about you is provided during your onboarding as a user and during your entering into transactions with Koi in the context of a digital currency or other financial asset trades. This Personal Information, not available publicly, comes from the following sources:
- Information you provide to us when you fill out account opening documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information;
- Information from your transactions with us, such as your trade amount, digital currency type, trade direction, sale proceeds or investment amount, and wire instructions; and
- Any other identifying information we collect in fulfillment of our “Know Your Customer” and sanctions screening legal and regulatory requirements, including, without limitation, Section 326 of the USA PATRIOT ACT, which requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This federal requirement applies to all Koi counterparties and collected information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities.
How We Protect Your Information
We limit access to the Personal Information you provide us to those employees who need access to that information to provide you with services related to the transactions you are entering with Koi. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.
We use software, systems and procedures meeting generally accepted industry information security standards to protect your personal, financial and historical transaction information. While no security system is impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
The Importance of Being Accurate
If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services, to ensure security and to comply with legal and regulatory requirements. For example, we may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account and maintain your trading information. This information helps us improve our services to you.
An Ongoing Commitment to Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you close your account with us, Koi will retain your information for regulatory compliance, internal record-keeping and other legal purposes.
We Limit the Sharing of Information
To protect your privacy, we limit the sharing of your Personal Information outside of Koi. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:
- To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties, including TradeBlock, to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you enter into a financial transaction through the Koi Trading Site, we share your Personal Information with third party service providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform transaction execution and clearing services on your behalf. Pursuant to our agreements with these service providers, their ability to use your Personal Information is specifically limited to the service being provided.
- As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
- Koi may share information with our affiliates if the information is required to provide the services you request. An affiliate is a company that we own or control, or with which there is common ownership with us.
- Koi also reserves the right to disclose your Personal Information where required by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
Reviewing, Changing or Correcting Information
Privacy and the Internet
The following additional information will be of interest to you if you access a Koi Trading Site and/or one of its affiliates’ products or services through one or more of our websites:
Users of the Koi Trading Site are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.
Security is a cooperative effort between us and the users of the Koi Trading Site. Please remember that your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Koi, or by our service providers. This may be accomplished by using cookies, Web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within Koi and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a Koi client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions.
We may authorize certain third parties, including, without limitation, Google Analytics, Chartbeat and Mixpanel, to track usage and collect information about users and their activities on the Koi Trading Sites.