Legal

Privacy & Cookies Policy

Protecting Your Information • Supporting Trusted Learning

Cushy Forex & Commodity Academy (CFCA)

Operated under Cushy Integrated Business International

This document is an operational privacy-policy draft for CFCA and is intended to describe CFCA's information-handling practices. It should be reviewed against the specific technologies, payment providers, LMS providers and legal requirements applicable to CFCA before publication as a final legal document.

1. Who we are

Cushy Forex & Commodity Academy (CFCA) is a financial-market education and training institution operated under Cushy Integrated Business International. We provide educational programmes, learning resources, practical training, assessments, student support, online and offline classes, and related educational services through our website, learning platforms and communication channels.

2. Scope of this policy

This Privacy & Cookies Policy explains how we collect, use, store, protect and disclose personal information when you visit cushyacademy.com, register for a programme, use our learning platforms, communicate with us, make payments, participate in our classes or otherwise interact with CFCA services.

3. Personal information we may collect

Depending on how you interact with us, we may collect: identity information such as your name; contact information such as email address, telephone number and address; student and educational information such as programme selected, enrolment details, attendance, assignments, assessments and certificates; account and login information; payment and transaction information processed through our payment providers; technical information such as IP address, browser, device and operating-system information; communications and enquiries; and marketing preferences and consent records.

4. How we use personal information

We may use personal information to process registrations and enrolments; deliver courses and learning resources; administer classes, assessments and certificates; provide student support; process payments and related records; maintain and improve our website, LMS and educational services; communicate about classes, schedules, assignments, account matters and service updates; protect our systems and users against fraud, abuse and security threats; send marketing communications where permitted and, where required, with your consent; and comply with applicable legal obligations and protect our rights.

5. Financial-market education disclaimer

CFCA provides educational and informational content relating to forex, commodities, gold, silver, oil, cryptocurrency and other financial markets. Our educational materials are not a guarantee of trading profits and do not constitute personalised investment, financial, legal or tax advice. Trading financial markets involves substantial risk, and individual results vary. Enrolment in a CFCA programme does not create a promise or representation that a student will achieve any particular trading outcome.

6. Legal bases for processing

Where applicable, we process personal information on the basis of performing a contract or providing requested services; obtaining and relying on consent; complying with legal obligations; pursuing legitimate operational, security and educational interests; and protecting the rights, safety and integrity of CFCA, our students and our services.

7. Information sharing

We do not sell personal information. We may share information, where reasonably necessary, with trusted service providers that support our operations, including payment processors, hosting and cloud providers, learning-management and education technology providers, email and communication services, analytics providers, cybersecurity and authentication services, professional advisers and other contractors. We may also disclose information where required by law or where necessary to protect rights, safety, property or the integrity of our services.

8. Legal and regulatory disclosures

We may disclose personal information when required by applicable law, regulation, court order or lawful governmental request, or when we reasonably believe disclosure is necessary to prevent fraud, abuse, unlawful activity or threats to people or property, or to establish, exercise or defend legal rights.

9. International data transfers

Because CFCA may use service providers and technology infrastructure located in different countries, personal information may be processed or stored outside the country in which you live. Where applicable, we will take reasonable steps to ensure appropriate safeguards are applied to such transfers and processing.

10. Information security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. Access to personal information is limited to people and service providers who reasonably need it for legitimate purposes. No internet transmission or electronic storage system can be guaranteed to be completely secure.

11. Account security

Where you create an account, you are responsible for maintaining the confidentiality of your login credentials and for promptly notifying CFCA if you believe your account has been compromised. Do not share passwords or authentication information with unauthorised persons.

12. Data retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide services, maintain educational and transaction records, resolve disputes, enforce agreements, maintain security and comply with applicable legal, tax or regulatory requirements. Retention periods may therefore vary depending on the type and purpose of the information.

13. Cookies and similar technologies

Our website and digital services may use cookies and similar technologies such as pixels, SDKs, local storage and related tracking technologies. These technologies may help us operate the website, remember preferences, understand usage, improve services, maintain security and, where permitted, measure or personalise marketing.

14. Types of cookies

Strictly necessary cookies help the website operate and support security and authentication. Performance and analytics cookies help us understand how visitors use our website. Functionality cookies remember preferences and improve the user experience. Targeting or advertising technologies, where used and permitted, may help measure campaigns or deliver more relevant communications. Cookie duration may vary depending on the technology and purpose.

15. Third-party services and technologies

CFCA may use third-party technology and service providers for functions such as payments, website hosting, learning delivery, analytics, communication, authentication, security and marketing. These providers may process information according to their own privacy policies and contractual obligations. CFCA will seek to use providers appropriate to the services being delivered and the information involved.

16. Social media and external platforms

Our website or communications may contain links, buttons or integrations connected with third-party websites and social-media platforms. Interacting with those services may allow the third party to collect information according to its own terms and privacy practices. CFCA does not control the privacy practices of independent third parties.

17. Student testimonials, photos and success stories

CFCA may invite students to provide testimonials, photographs, videos or success stories for educational or promotional purposes. We will seek appropriate permission or consent before publicly identifying a student in promotional material where such permission is required. Students are not required to provide a testimonial merely because they enrol in a CFCA programme.

18. Student assignments and educational work

We may collect and process assignments, projects, assessments and other educational work for teaching, grading, feedback, certification, quality assurance and programme administration. We will not intentionally publish identifiable student work for public promotional purposes without appropriate permission where required.

19. Your privacy rights

Depending on applicable law, you may have rights to request access to personal information we hold about you, request correction of inaccurate information, request deletion where legally available, request restriction of certain processing, object to certain processing, request data portability where applicable, withdraw consent where processing is based on consent, and opt out of marketing communications. Legal rights may be subject to applicable exceptions and limitations.

20. Marketing communications

You may receive educational, programme, service or promotional communications from CFCA. Where required, we will obtain appropriate consent before sending certain marketing communications. You may unsubscribe from marketing messages by using the available unsubscribe mechanism or contacting us. Service and account-related communications may continue where necessary to provide requested services.

21. Children and minors

Our programmes and services are not intended to be directed to children in circumstances where applicable law requires parental or guardian consent. Where we become aware that personal information has been collected from a child in circumstances where collection was not appropriate, we will take reasonable steps to address the situation.

22. Accuracy of personal information

Please provide accurate and current information when registering or communicating with CFCA and notify us when important information changes. We may rely on the information you provide for enrolment, communication, certification, payment and service administration.

23. Data breaches and security incidents

If CFCA becomes aware of a personal-data security incident, we will assess it and take reasonable steps appropriate to the circumstances, including containment, investigation, remediation and notifications where required by applicable law.

24. Third-party websites

Our website may contain links to third-party websites or services. This Policy applies to CFCA-controlled services and does not govern independent third-party websites. We encourage users to review the privacy policies of any third-party service they access.

25. Changes to this policy

We may update this Privacy & Cookies Policy from time to time to reflect changes in our services, technology, legal requirements or privacy practices. The updated version will be made available through our website, and the effective date may be updated when material changes are made.

26. Contact us

For privacy questions, requests or concerns, please contact Cushy Forex & Commodity Academy (CFCA), operated under Cushy Integrated Business International.

27. Acknowledgement

By using CFCA services, submitting information, registering for a programme or interacting with our website and learning platforms, you acknowledge that you have had the opportunity to review this Privacy & Cookies Policy. Where consent is legally required for a particular processing activity, we will seek that consent through an appropriate mechanism.