FXTool Privacy Policy

Effective Date: October 1, 2025

Introduction

Welcome to FXTool. We take the protection of your personal information and privacy seriously. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you register for an account, browse the platform, purchase or download products, use license verification services, or submit support tickets. It also describes the rights you have in relation to your personal information.

Please read this Privacy Policy carefully before using our services. By checking "Agree and Continue," completing registration, or otherwise accessing or using the platform, you acknowledge that you have read and agree to the terms of this Privacy Policy.

1. Definitions

1. Platform refers to the software tools marketplace operated by FXTool, including but not limited to the website, web pages, API endpoints, and any future client applications, through which software tools are displayed, distributed, transacted, and supported.
2. Operator (also referred to as "FXTool," "we," "us," or "our") refers to the entity that operates FXTool and its affiliates.
3. User (also referred to as "you" or "your") refers to any natural person, legal entity, or organization that registers for, logs in to, or uses the services provided by the Platform.
4. Personal Information refers to any information recorded electronically or by other means that relates to an identified or identifiable natural person. It does not include information that has been anonymized.
5. Sensitive Personal Information refers to personal information that, if disclosed or unlawfully used, could endanger the personal safety or property of an individual, damage personal dignity, or result in discriminatory treatment.
6. De-identification refers to the process of treating personal information so that the data subject cannot be identified without the use of additional information.
7. Anonymization refers to the process of irreversibly treating personal information so that the data subject can no longer be identified and the information cannot be restored to its original form.

2. How We Collect and Use Personal Information

We collect and use your personal information only to the extent necessary to operate the Platform and provide our services.

2.1 Account Registration and Login

To enable account registration, login, and account management, we may collect the following information:

• Email address or other login identifiers;
• Encrypted password hash or authentication credentials;
• Basic account information, such as display name, avatar, and language preference.

2.2 Orders, Payments, and Delivery

To process orders, reconcile payments, deliver digital products, activate licenses, handle refunds, and provide after-sales support, we may collect the following information:

• Order information: products purchased, price, currency, timestamp, and order status;
• Payment information: such as payment channel identifier, transaction reference number, and callback status (excluding your full bank card number or security code);
• Delivery and download information: such as download records, file versions, and license key issuance and usage status.

2.3 License Verification Services

To perform license verification, manage account binding limits, handle rebinding requests, and support anti-fraud and risk control measures, we may collect the following information:

• License keys or other license-related identifiers you submit;
• Trading platform account information you enter or bind, such as MT4 or MT5 account numbers;
• Verification request metadata, such as request timestamp, IP address, basic device or client information, and log records.

2.4 Developer Identity Verification (Sensitive Personal Information)

If you apply to become a developer on the Platform, we are required to verify your identity in accordance with applicable laws and regulations governing online commerce. For this purpose, we will collect the following Sensitive Personal Information:

• Full legal name;
• Government-issued identification number.

This information is verified through a third-party identity verification service and is used solely to confirm your identity. We will not use this information for any other purpose and will apply enhanced security measures, including encrypted storage, to protect it. If you do not apply to become a developer, we will not collect this information.

2.5 Support Tickets, Reviews, and Customer Service

To address your inquiries, resolve disputes, and provide technical support, we may collect the following information:

• Content of support tickets, feedback, contact details, and any attachments you submit;
• Product reviews, ratings, and related moderation information.

2.6 Security and Operational Logs

To maintain the security, stability, and compliance of the Platform, and to prevent fraud, attacks, abuse, and abnormal behavior, we may collect the following information:

• Access logs, such as access timestamps, page paths, and error messages;
• Security logs, such as anomalous login attempts, request frequency, and unusual download patterns and other risk signals.

2.7 Additional Disclosures

If we use your personal information for purposes not described in this Privacy Policy, or use information collected for a specific purpose for a different purpose, we will separately notify you and obtain your consent in accordance with applicable law, unless otherwise permitted by law or regulation.

3. Cookies and Similar Technologies

We use the following types of cookies:

• Strictly Necessary Cookies: Used to maintain your login session and ensure the basic functionality of the Platform. These cookies cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings.
• Analytics Cookies: Used to collect aggregated statistics on site traffic and usage patterns to help us improve our services.

You can manage or delete cookies through your browser settings. Please note that disabling strictly necessary cookies may affect your ability to use core features of the Platform, such as staying logged in.

4. How We Share, Transfer, and Disclose Personal Information

4.1 Sharing

We do not sell your personal information to third parties. We may share your information only in the following circumstances and only to the extent necessary:

• With payment service providers, to process payments and reconcile transactions (limited to order and transaction identifiers);
• With email service providers, to deliver notifications and communications (limited to recipient addresses and message content);
• With cloud infrastructure and security service providers, to maintain hosting, security monitoring, and alerting (limited to operational logs and system data);
• As required by applicable laws, regulations, court orders, or government authorities, or as necessary to protect the public interest.

4.2 Transfers

As a general rule, we do not transfer your personal information to third parties. In the event of a merger, acquisition, division, or asset transfer, we will notify you in accordance with applicable law and require the receiving party to comply with the terms of this Privacy Policy.

4.3 Public Disclosure

We will not publicly disclose your personal information unless required by applicable law or regulation, or unless we have obtained your explicit, separate consent.

5. How We Store Personal Information

5.1 Retention Periods

We apply the following retention periods based on data type:

• Account information: Retained for the duration of your account's existence. Deleted within 30 days after account closure.
• Order and transaction data: Retained for 3 years from the date of transaction completion, to meet tax, financial, and dispute resolution requirements.
• Identity verification information (full legal name and identification number): Retained for the duration of the developer's active status. Retained for an additional 3 years after developer status is terminated.
• Access logs and security logs: Retained for 6 months.
• Support tickets and review data: Retained in accordance with your account status. Deleted within 30 days after account closure.

After the applicable retention period expires, we will delete or anonymize your personal information, unless a longer retention period is required by applicable law or regulation, or is necessary for the fulfillment of a legal obligation.

5.2 Storage Location

Your data is stored on the servers used to operate the Platform. We apply reasonable technical and organizational measures to ensure data security, including encrypted storage, access controls, and security audits.

6. How We Protect Personal Information

We implement reasonable and appropriate security measures to protect your personal information against unauthorized access, use, disclosure, alteration, destruction, or loss. These measures include, but are not limited to, access controls, encryption in transit, security audits, and least-privilege access management.

Please be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.

In the event of a personal information security incident, we will take reasonable remedial measures and notify affected users in a timely and appropriate manner.

7. Your Rights

Subject to applicable laws, regulations, and Platform policies, you have the following rights with respect to your personal information:

1. Access, correction, and deletion: You may request to access, correct, or delete your personal information.
2. Account closure: You may request to close your account.
3. Data portability: Where applicable, you may request a copy of your personal information in a commonly used, machine-readable format.
4. Withdrawal of consent: You may withdraw your consent to the processing of your personal information at any time, without affecting the lawfulness of processing carried out prior to your withdrawal.

Effect of withdrawing consent: If you withdraw consent to certain essential data processing activities (such as those related to license verification), we may no longer be able to provide you with the corresponding services or the license functionality for products you have purchased. However, this will not affect the lawfulness of any processing carried out prior to your withdrawal.

You may exercise these rights through the relevant features on the Platform or by submitting a support ticket. To protect your account security, we may verify your identity before processing your request.

8. Protection of Minors

Our services are intended for users who have full civil capacity. If you are a minor, please use the Platform only with the consent and guidance of a parent or legal guardian. We will process any relevant information in accordance with applicable laws and regulations.

9. Third-Party Links and Services

The Platform may contain links to third-party websites, products, or services. These third parties maintain their own, independent privacy policies and data processing practices. We recommend that you review the privacy policy of any third-party service before using it. The Operator is not responsible for the data processing practices of any third party.

10. Risk Disclosure and Limitation of Liability

1. The products and services available on the Platform include both first-party products and products developed by third-party developers. The Operator processes personal information in accordance with the principle of data minimization. However, we do not guarantee against consequences arising from user actions, the user's own device or network environment, or third-party services.
2. To the maximum extent permitted by applicable law, the Operator shall not be liable for any interruption, delay, or loss of data transmission caused by force majeure, third-party actions, or factors beyond the Operator's reasonable control, nor for any indirect losses arising therefrom.
3. Where the Operator is found liable under applicable law, the Operator's total aggregate liability shall not exceed the actual amount paid by you for the specific product or service giving rise to the dispute, unless otherwise mandated by applicable law.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, applicable laws and regulations, or risk management requirements. We will notify you of any material changes through announcements, in-platform notifications, or other reasonable means. Your continued use of the Platform after such updates constitutes your acceptance of the revised Privacy Policy.

12. Contact Us

If you have any questions, comments, or complaints regarding this Privacy Policy, please contact us through the contact information provided on the Platform or by submitting a support ticket.

13. General Provisions

1. If any provision of this Privacy Policy is held to be invalid or unenforceable, such invalidity or unenforceability shall not affect the validity or enforceability of the remaining provisions.
2. In the event of any conflict between a provision of this Privacy Policy and mandatory provisions of applicable law, the applicable law shall prevail.