Privacy Policy

Definitions

Personal data means any information relating to an identified or identifiable person. Usage data means technical information collected automatically when you use the site — pages viewed, timestamps, device and browser type, approximate region. Cookies are small text files stored on your device. Data controller is the entity that decides why and how personal data is processed — here, [RAISON SOCIALE], trading as Couponeau App, , Ottawa, Canada; contact: [email protected]. A processor processes data on the controller's behalf under contract.

Collection and use of information

We collect the personal data you give us directly through forms and account activity. The categories are:

• Identity and contact data — first name, last name, phone number, email address, and the content of your request or message.
• Account data — login email, password (stored only as a hash), security settings, 2FA status.
• Verification data — identity documents, address documents and verification results, collected under our AML/KYC policy.
• Transaction data — deposits, withdrawals, trades executed through your account and their timestamps.
• Usage data — pages visited, feature interactions and technical logs.

Legal bases for processing

We process personal data on the following bases: performance of a contract (operating your account, executing your instructions, providing support); compliance with a legal obligation (identity verification, record-keeping and reporting under AML/CTF requirements in France); legitimate interest (service security, fraud prevention, product improvement — always balanced against your rights); and, separately, consent, which you give — and can withdraw at any time — for marketing communications.

Cookies

We use a small number of strictly necessary cookies: session cookies that keep you signed in securely, and security cookies used to distinguish you from attackers. We also store your interface preferences. We do not run third-party advertising trackers. You can clear or block cookies in your browser; the only casualty is your login session.

Retention periods

• Identity and contact data: for the life of the account, then as required by law after closure.
• Verification (KYC) records: for the statutory retention period applicable in your jurisdiction after account closure.
• Transaction records: for the statutory financial-record retention period.
• Support correspondence: up to 3 years after the matter closes.
• Usage and log data: up to 12 months, then aggregated or deleted.
• Marketing consents: until withdrawn, plus a short record of the withdrawal itself.

Data transfers and disclosure

Your data may be shared with: the licensed entity executing trades on your behalf; affiliated companies within our corporate group, for support and compliance functions; IT and payment providers under written processor contracts (hosting, email delivery, identity verification, payment processing); and regulators, financial intelligence units, auditors or courts where the law requires or authorises disclosure. Transfers to providers outside your jurisdiction are protected by contractual safeguards. We do not sell personal data — to anyone, ever.

Service providers and analytics

We work with a short list of processors: hosting and infrastructure, transactional email, identity verification and payment processing. We use privacy-preserving analytics — aggregate counts of page visits and feature usage without building individual advertising profiles. No cross-site retargeting or advertising networks are used on this site.

Security

Personal data is encrypted in transit (TLS) and at rest. Access is limited to staff who need it for their role, under individual logins, with access logged. Payment details are handled by our payment providers and never stored in full on our systems. More detail is on the Security page.

Your rights

You can exercise the following rights by emailing [email protected] from your registered address: access — a copy of the personal data we hold about you; rectification — correction of inaccurate data; erasure — deletion where no legal obligation requires us to keep the data (verification and transaction records are the usual exceptions); restriction — a pause on processing while a dispute is resolved; and objection — to processing based on legitimate interest, and to marketing at any time. We answer rights requests within 30 days.

Links to third-party sites

Our pages link to external resources — for example, payment providers' own websites. Those sites have their own privacy practices; this policy covers only Couponeau App. We encourage you to read each provider's policy before sharing data with them.

Children's privacy

The platform is not offered to anyone under 18 (or under the age of legal capacity in your jurisdiction). We do not knowingly collect data from children; if we learn that an account belongs to a minor, it is closed and the data deleted.

Changes to this policy

We may update this policy as the service or the law changes. The current version is always on this page with its effective date; material changes are announced to registered clients by email at least 14 days before they take effect.

Contact us

Privacy questions, requests and complaints go to [email protected], addressed to the Support client & Conformité department. If you are in Australia, you may also raise privacy concerns with the OAIC; if in Canada, with the Office of the Privacy Commissioner of Canada, after our internal process.