Privacy Policy

CortexProp LLC ("CortexProp", "we", "us", "our"), a Limited Liability Company incorporated under the laws of Saint Vincent and the Grenadines under Company No. 4430 LLC 2026, with registered office at The Financial Services Centre, Stoney Ground, Kingstown, Saint Vincent and the Grenadines, trading under the brand name CortexProp, takes your privacy seriously.

This Privacy Policy explains how we collect, use, share, store and protect your personal data when you use our website www.cortexprop.com, our mobile and desktop applications, our trading platforms (CortexProp Terminal, MetaTrader 4 / 5, cTrader, Match-Trader), our AI services, our educational Academy, our Live Trading Rooms, our community channels and any other service we provide (collectively the "Platform" or the "Services").

This Privacy Policy is published as a stand-alone document and complements Articles 41 to 44 and Annex 4 of the General Terms and Conditions ("Terms") of CortexProp LLC. In case of conflict between this Privacy Policy and the Terms, this Privacy Policy prevails in respect of the processing of personal data.

By using the Platform, you confirm that you have read this Privacy Policy and understood how your personal data is processed. If you do not agree with this Privacy Policy, please do not use the Platform.

The data controller of your personal data is:

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy and our data-protection practices. The DPO can be contacted at dpo@cortexprop.com.

Saint Vincent and the Grenadines does not currently have a comprehensive statutory data-protection regime equivalent to the EU GDPR. Notwithstanding, CortexProp LLC voluntarily commits, on a best-practice basis and to the extent extra-territorially required, to apply the standards of the following frameworks where they apply to you:

Where the mandatory data-protection law applicable to you grants you greater rights than this Privacy Policy, the mandatory law prevails in respect of your data.

4.1 Identity and contact data

4.2 KYC and AML verification data

4.3 Account and platform usage data

4.4 Trading and behavioural data

4.5 Payment data

4.6 Communication data

4.7 Marketing data

4.8 Technical and analytics data

We process your personal data only where we have a valid legal basis to do so. The following table summarises the main purposes and the legal bases we rely on under the GDPR (and equivalents under the UK GDPR, CCPA, PDPA and LGPD).

You have the right to object to processing based on legitimate interest at any time (see Section 9 below).

6.1 AI Services and behavioural modelling

When you use our AI Services (CortexProp AI Lite, Pro or Master tiers), we process your trading and behavioural data to generate personalised insights, alerts and recommendations. This includes:

6.2 No automated individual decisions with legal effect

We do not make automated individual decisions concerning you that produce legal effects or similarly significantly affect you within the meaning of Article 22 GDPR. Decisions on rule breaches, withholding or denial of Rewards, suspension or termination of your Account are always subject to final assessment by an authorised member of our Risk & Compliance team.

6.3 Profiling for fraud prevention

We use profiling techniques (IP-address analysis, device fingerprinting, behavioural biometrics, velocity checks, cross-account correlation) for the legitimate purpose of fraud prevention, AML compliance and Platform integrity. You have the right to object to such profiling, but please note that without these techniques we may be unable to provide you with the Services.

6.4 Right to opt out of AI training

If you do not want your anonymised trading and behavioural data to be used to train and improve our AI models, you may opt out by writing to privacy@cortexprop.com. Please note that opting out may make certain personalised features (e.g. personalised AI models in CortexProp Elite) unavailable.

6.5 AI explainability

You have the right to request available information on the logic of an AI model that generated a particular output relating to you. We will provide such information to the extent compatible with the protection of our trade secrets.

We share your personal data only with parties who need it to provide the Services, comply with the law or assist in our legitimate interests. We require all recipients to keep your data confidential and to process it only for specified purposes.

7.1 Categories of recipients

7.2 We do not sell your personal data

We do not sell your personal data and we do not "share" personal data for cross-context behavioural advertising as defined under the CCPA/CPRA. California residents have the right to opt out of any future selling or sharing — see Section 9 below.

7.3 Representative list of key processors

The current list is available on request at privacy@cortexprop.com.

Because our Platform serves Users globally and our processors are located in multiple jurisdictions, your personal data may be transferred to, processed in, or stored in countries outside your country of residence, including the United States, the European Union, the United Kingdom, Singapore, Canada and Saint Vincent and the Grenadines.

When we transfer personal data of EU/EEA residents to a country that has not been the subject of an adequacy decision by the European Commission, we put in place adequate safeguards under Article 46 GDPR, in particular:

For UK residents, we use the UK International Data Transfer Agreement (IDTA) or the UK Addendum to SCCs. You may obtain a copy of the relevant safeguards by contacting privacy@cortexprop.com.

9.1 Rights under GDPR / UK GDPR

9.2 Rights under CCPA / CPRA (California residents)

9.3 Rights under PDPA (Singapore) and LGPD (Brazil)

PDPA grants Singapore residents rights of access, correction and withdrawal of consent. LGPD grants Brazilian residents rights of access, correction, anonymisation, blocking, deletion, portability and information about sharing.

9.4 How to exercise your rights

To exercise any of the above rights, please submit a request through the "Data Subject Request" form in your Account settings, or e-mail privacy@cortexprop.com with the subject line "Privacy Request".

We will respond within: 1 month (GDPR/UK GDPR) · 45 days (CCPA/CPRA) · 30 days (PDPA) · 15 days (LGPD). Exercise of rights is free of charge, except for manifestly unfounded or excessive requests.

We retain personal data only for as long as necessary for the purposes for which it was collected and to comply with our legal and regulatory obligations.

After the retention period expires, we either delete or fully anonymise the data so that you can no longer be identified.

We use cookies and similar technologies to operate the Platform, remember your preferences, analyse usage and (with your consent) deliver marketing. Cookies are categorised as: Essential (always active), Functional, Analytics and Marketing (all three require consent).

When you first visit the Platform, a cookie consent banner allows you to accept all, reject non-essential, or choose specific categories. You can change preferences at any time via "Cookie Preferences" in the footer. The full detail is in our separate Cookie Policy.

We may send you marketing communications about new features, educational content, promotions and events via e-mail, push notifications, in-platform notifications and third-party advertising platforms (Meta, Google, LinkedIn, X).

You can unsubscribe at any time by clicking "unsubscribe" in any marketing e-mail, adjusting preferences in Account settings (Profile → Notifications), or contacting privacy@cortexprop.com.

The Platform is not directed at children under the age of eighteen (18). We do not knowingly collect personal data from anyone under 18. If you become aware that a child has provided us with personal data, please contact privacy@cortexprop.com and we will take steps to delete the data and terminate any associated account.

We implement appropriate technical and organisational measures to protect your personal data, including:

In the event of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within seventy-two (72) hours of becoming aware (Article 33 GDPR), notify affected data subjects where the breach is likely to result in a high risk (Article 34 GDPR), and maintain an internal register of all data-breach incidents.

If you believe we have not handled your personal data in accordance with applicable law, please first contact us at privacy@cortexprop.com. If not satisfied, you have the right to lodge a complaint with:

We may update this Privacy Policy from time to time. Material changes will be communicated by e-mail, in-platform notification, and a prominent notice on the Platform at least thirty (30) days before the new version takes effect. Continued use of the Platform after the effective date constitutes acceptance. We archive previous versions — contact privacy@cortexprop.com to request a prior version.

If you act as a Strategy Provider in our Copy Trading service, your trading performance metrics, handle (pseudonym) and an anonymised strategy description may be displayed on public leaderboards. You may opt out via the "Anonymise my profile" function in Account settings.

If you are a mentor or lecturer in our Academy, your name, photograph and biographical information may appear in marketing materials. You have the right to request removal at any time.

If you participate in our Affiliate Programme, the Affiliate Agreement applies, including processing of your payment and conversion-tracking data.

If you choose to receive Reward pay-outs in stablecoins (USDT, USDC), we process your blockchain wallet address. We perform on-chain analytics through reputable third-party providers (Chainalysis, Elliptic, TRM Labs) for AML/CFT compliance, sanctions screening (OFAC, EU, UN sanctioned addresses), and detection of mixers, tumblers and other indicators of high-risk on-chain origin. We retain on-chain analysis results for 5 years in line with our AML retention policy.

Postal address: CortexProp LLC – Privacy Office, P.O. Box 1823, Kingstown, VC0 100, Saint Vincent and the Grenadines

Registered office: The Financial Services Centre, Stoney Ground, Kingstown, Saint Vincent and the Grenadines