Privacy and Cookies Policy

Last Updated on March, 2024

This Privacy and Cookie Policy (the “Policy”) govern the access to and use of all parts of the platform (the “Platform”) and the Services (the “Services”) branded as FINKBAY LTD (“Platform”, “KoinBay”, “We”, “Us”, or “Our”) operating under the license of Zenit World LTD (“White Label Service Provider”), holding license number BFX2024011 and incorporated on February 12, 2024, pursuant to the International Business Companies Act 2014 of the Autonomous Island of Mwali (Mohéli), Comoros Union and refers to the domain, all documents, data, materials or other information made available on the Platform.

This Privacy Policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any Personal Data we collect from You, or that You provide to us, will be processed by us and applies to all users (“User”, “Users”, “You” or “Your” “Yourself ”) using KoinBay Platform. By accessing our Platform, registering with us, or submitting information to us You consent that You have read and understood our collection, storage, processing, use, transfer, and disclosure of Your Personal Data in accordance with this Privacy Policy.


1.1. “Account” refers to the User’s account opened on the KoinBay Platform, according to the terms and conditions in this Policy, and any other applicable rules.

1.2. “Collaborative Partners” refers to the third-party partners with whom KoinBay collaborates, where You utilize Your KoinBay Account and relevant credentials to access their Services.

1.3. “Personal Data” refers to any information that relates directly or indirectly to a natural or legal person, who is identified or identifiable from that information, or from that and other information in the possession of a data User, including any sensitive Personal Data and any content created by the User.

1.4. “User” refers to any natural or legal person accessing and creating an Account on the KoinBay Platform according to applicable terms and conditions, using any kind of technological device that allows reading, listening, and/or watching information on the Platform and/or interacting with this information in an active or passively way.

1.5. “Platform” refers to the domain “” and its subdomains. Any kind of redirection link to any kind of website and or Platform controlled by Collaborative Partners is not covered by this Policy, therefore You agree to check the relevant privacy and cookies policy from this Collaborative Partners.

1.6. “Cookies” refers to a piece of information sent to Your browser by a website You visit. You can set Your browser to accept all cookies, to reject all cookies, or to notify You whenever a cookie is offered so that You can decide each time whether to accept it or otherwise. For further details on cookies, please visit All About Cookies.


2.1. We know and understand how important it is for You to understand how KoinBay collects, stores, processes, shares, and uses Your data. KoinBay respects and protects the privacy of Users’ data in our Platform.

2.2. The purpose of this Policy is to describe how KoinBay collects, processes, and manages Users’ data through the Platform to offer KoinBay Services.


3.1. By accessing and using Our Platform, You are consenting and accepting the terms of this Policy, the terms and conditions of the Service, and any other supplementing document provided related to the present document. If You do not agree or consent to receive our cookies, may in some cases preclude You from using the KoinBay Platform, or Services, or negatively affect the display or function thereof.

3.2. In any case, KoinBay will not hold any responsibility for any errors, bugs, or malfunctions on the Platform regarding the information displayed and/or its functions, caused by You by not allowing our cookies.


4.1. Users understand and acknowledge that when they access specific Services provided by Collaborative Partners through the KoinBay Platform, they shall be subject to the individual privacy policy of each respective Collaborative Partners. The privacy practices, data collection, processing, and usage of information by the Collaborative Partners are governed solely by their own privacy policies. KoinBay does not have any discretion or control over the privacy practices of the Collaborative Partners.

4.2. Users grant KoinBay permission to use their data and information as required to create and maintain an Account on the Platform. This information includes name, email address, contact details, and any other relevant information as specifically detailed in clause 5, required for account registration and management. KoinBay may share Your Personal Data with third parties, as described in clause 7.

4.3. Users acknowledge that KoinBay will use the provided Personal Data to generate login credentials, such as username and password, for accessing the Platform. These login credentials will enable Users to access the various Services provided by Collaborative Partners through the Platform.


5.1. Your Personal Data is collected and stored with us in order to provide, develop, and enhance our products and Services including technical infrastructure, security, compliance, fraud prevention, and customer support. KoinBay is committed to exercising due diligence when dealing with every User and in the course of conducting business, KoinBay complies with all the applicable Laws and regulations.

5.2. The Personal Data KoinBay collects from Users are:

5.2.1. Users - Natural Person; Full name; Date of Birth; Email Address; Gender; Residence Address; Nationality; Zip Code; Telephone number; Profession and employment details; Net worth; Income; National Identity Card; Driving License; Passport details; Proof of Residences; Salary Certificate; Information about Your income and wealth including details about Your assets and liabilities (Source of funds), account balances, trading statements, tax and financial statements; Sanction & PEP questionnaire; Audio or video recordings; Wallet Address; Transaction details;

5.2.2. Users - Legal Entity Company name; Company registration number; Country of Incorporation; Country of operation; Registered address; Details of the authorized person of the entity; UBO details and proof of address; A copy of the certificate of incorporation; Shareholder registry; Director registry; VAT identification; General information about the nature of business; General information about the nature of business; Corporate Expected Trading Volume (per week); Source of Funds Verification documents; A letter of authorization issued to the individual performing on behalf of the entity; PEP and Sanction Questionnaire; Passport copies of all directors, shareholders, and Key controllers; Memorandum of Association; Article of Association; Audited Financial Statement; Audio or video recordings (authorized person/ director/shareholder); Wallet Address; Transaction Details;

5.2.3. Browser Information IP address; Login information; Browser type and version; Time zone setting; Platform; Operating system; Transaction history; Pages accessed and links clicked; Trading experience information, including Your understanding of relevant risks and ability to withstand financial loss.

5.3. We obtain this information in a number of ways through Your use of Our Services or other dealings with us including through any of Our websites, account opening applications, contact forms, telephone, internet chat systems, our practice account sign-up forms, webinar sign up forms and information provided in the course of ongoing client service correspondence. We may also collect information about You from third parties either through customer due diligence providers, sanctions screening providers, credit reference agencies, publicly available sources, or screened third-party data lists.

5.4. We also keep records of Your trading behavior, including a record of suspicious transactions and orders, Your preference for certain types of products and services, Your financial transactions, the products You trade with us and their performance, historical data about the trades, and investments You have made including the amount invested. We will use Your Personal Information to provide You with products and services, or information about our products and services, and continuously review Your ongoing needs once You open an account with us or subscribe to information resources on our sites or applications (e.g. blogs, newsletters, etc.).

5.5. We also collect, use, and share statistical or demographic data for many purposes (“Aggregated Data”). Aggregated Data may be derived from Your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal Your identity. For example, we may aggregate Your usage data to calculate the percentage of users accessing a specific website feature. Where we combine or connect Aggregated Data with Your Personal Data so that it can directly or indirectly identify You, we treat the combined data as Personal Data which will be used in accordance with the law and this Privacy Policy.


6.1. To communicate with the User;

6.2. To comply with legal and regulatory compliance;

6.3. To detect and prevent fraud and credit risks;

6.4. To provide, troubleshoot, and improve KoinBay Services;

6.5. To enforce our terms in our Terms of Use

6.6. To provide customer Services;

6.7. To ensure quality control;

6.8. To ensure network and information security;

6.9. To enhance and personalize User experience;

6.10. To facilitate corporate acquisitions, mergers, or transactions;

6.11. To engage in marketing activities;

6.12. For transaction Services;

6.13. Purposes for which KoinBay seeks User’s consent;


7.1. KoinBay may share Your Personal Data with Collaborative Partners, including but not limited to partners, business suppliers, distributors, and subcontractors, when it is necessary for the delivery of Koinbay Services, or when there is a legal basis to do so. KoinBay complies with the applicable Data Protection and legal norms, and only shares information in the following circumstances:

7.1.1. With applicable regulatory bodies of the Commonwealth of Dominica;

7.1.2. With Collaborative Partners, KYC/AML service providers for identity verification purposes when the User is in an onboarding process;

7.1.3. With service providers under contracts to operate the business. For instance; cloud Storage, network infrastructure, security, customer support, marketing, and data analytics;

7.2. In the event that Our Platform undergoes a merger, acquisition, or any other form of corporate transition, User information and data held by the Platform may be part of the transferred assets. By using our Platform, You acknowledge and consent that such transfers may occur, and that any acquirer or merging entity may continue to process Your personal information as set forth in this Privacy Policy. We will make reasonable efforts to notify You of any such transfer and any material changes to the handling of Your personal information resulting from the transaction. However, You understand and agree that You may not be notified in advance of any changes to the privacy practices of the Platform.

7.2.1. The transferred data will remain subject to the terms of this Privacy Policy or any subsequent updates unless otherwise agreed upon in accordance with applicable data protection laws. The receiving entity will handle the data in compliance with its own data protection protocols and regulations. Our Platform reserves the right to transfer personal information at its sole discretion, ensuring that such transfers adhere to relevant data protection regulations and standards. If You have any concerns about the transfer of Your data in the context of a corporate transaction, please contact us using the information provided in the "Contact Information" section of this Privacy Policy.

7.3. By proceeding to use the Platform, you explicitly agree and acknowledge that, as part of our business strategies for growth and improvement, we may acquire other platforms, services, or entities. Consequently, users from these acquired platforms may be integrated into Our Platform. Your continued use of Our Platform signifies Your acceptance of and acknowledgment regarding the potential inclusion of users from acquired platforms. We assure you that we will take all necessary measures to uphold data protection and privacy standards during the integration process. If you do not agree with the Terms outlined in this clause, we advise You to discontinue the use of the Platform.

7.4. Each Collaborative Partner may have its own data transfer clauses, terms of use, and privacy policies governing how Your information is handled, processed, and shared. KoinBay is advising You to consult the respective privacy policies of the Collaborative Partners for more detailed information. It may include their practices and instructions about how to opt out of certain options. By using our Platform to access the Services of Collaborative Partners, You acknowledge and agree to adhere to the data transfer clauses and privacy policies of those Collaborative Partners.

7.5. KoinBay is not liable for any disparities in eligibility criteria among Collaborative Partners. Users are encouraged to directly contact the relevant Collaborative Partners for clarifications on their access policies. User’s access to any Collaborative Partners through our Platform is contingent upon the User’s compliance with the respective Collaborative Partners, the applicable terms, conditions, laws, and regulations.


8.1. KoinBay maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, processing, use, transfer, and disclosure of the User’s Personal Data. KoinBay uses firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.

8.2. Personal Data collected may be stored and processed in Your region, and in any other country where KoinBay or its affiliates, subsidiaries, service providers, and Collaborative Partners have operating facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem.

8.3. KoinBay cannot ensure the security or privacy of data transmitted via email, phone, or SMS, till such data reaches the domain of our network since KoinBay has no access to the involved data until it reaches our domain.


9.1. KoinBay retains Personal Data for as long as it is needed for the purposes for which we collected it. KoinBay retains data for as long as You have an active KoinBay Account. Some information can be deleted from the Platform on request, however, KoinBay is obligated to retain either the original or an accurate copy of all data and information received from its Users in an easily accessible format for at least period of five (5) years subsequent to the termination of Your association with our Services, initiated at Your request.

9.2. KoinBay takes reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose of providing the Services for which it was processed. In certain circumstances, if required by law and/or law enforcement agencies, we may not destroy any personal records or data even though the prescribed period for retention shall have elapsed.

9.3. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to one (1) year from the expiry of the termination of our association with the User.


10.1. This Policy is governed by and shall be construed in accordance with the data protection laws of the Commonwealth of Dominica. Additionally, the highest standard of data protection, as set forth in the General Data Protection Regulation ("GDPR"), shall also apply to the processing of Personal Data covered by this Policy.

10.2. According to the GDPR, KoinBay provides privacy notices, in a concise, transparent, intelligible, and easily accessible form, written in clear and plain language, delivered in a timely manner; and provided free of charge.

10.3. If the Users are located in the European Economic Area (“EEA”), You will have the rights as described below.

10.4. You may request access to and receive information about the Personal Data KoinBay maintains about You, update and correct inaccuracies in Your Personal Data, restrict or object to the processing of Your Personal Data, have the information anonymized or deleted, as appropriate, or exercise Your right to data portability to easily transfer Your Personal Data to another company.

10.5. You may withdraw any consent You previously provided to us regarding the processing of Your Personal Data, at any time and free of charge. KoinBay will apply Your preferences going forward and this will not affect the lawfulness of the processing before You withdraw Your consent.

10.6. If You are located in the EEA, KoinBay will comply with applicable GDPR law when transferring Your Personal Data outside of the EEA.


11.1. Under certain circumstances, according to applicable laws and regulations, You have rights under data protection laws in relation to Your Personal Data as detailed below:

11.1.1. Request Access: This enables You to receive copies of Your Personal Data KoinBay holds about You and to check that we are lawfully processing it known as a "data subject access request". This enables You to have any incomplete or inaccurate data KoinBay holds about You. By correcting though we may need to verify the accuracy of the new data You provide to us.

11.1.2. Request Erasure: This enables You to request us to delete or remove Your Personal Data where there is no good reason for us to continue to process it. Nonetheless, there may be circumstances where KoinBay may be legally entitled to retain Your Personal Data in accordance with the terms of this Policy and/or any other AML/CFT reasons in accordance with the global standards.

11.1.3. Request to Restrict Processing: This enables You to restrict the processing of Your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, KoinBay will no longer process Your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. Be aware that restricting Your data processing can lead to the malfunction of our Services.

11.1.4. Request to Object Processing - You have the right to object to the processing of Your Personal Data where KoinBay is relying on a legitimate interest (or those of a Collaborative Partner) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You also have the right to object when KoinBay is processing Your Personal Data for direct marketing purposes.

11.1.5. Request to Transfer: Under Your request, KoinBay will provide You with Your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated information that You initially provided consent for us to use or where KoinBay used the information to perform a contract with You. Any request related to Personal Data held by the Collaborative Partner shall be directly addressed to the involved Collaborative Partner.


12.1. Whenever You visit our Platform, KoinBay will send a cookie to the device You are using to access our Platform, which may place tracking technologies on Your device, browser, or the webpage You are viewing, in order to personalize Your experience, understand usage patterns, provide, improve, and secure KoinBay Platform. Your device automatically stores the Cookie in a file located within Your browser allowing us to recognize Your device upon future access. Cookies set by our operators are called “First-party cookies”. Cookies set by parties other than our Platforms are called “Third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website for instance such as advertising, interactive content, and analytics.

12.2. We use cookies to:

12.2.1. Optimize Your trading experience, including remembering Your preferences, location, preferred language, browser and other details;

12.2.2. Authenticate Your identity for security purposes;

12.2.3. Maintain our website and certain functions available on it;

12.2.4. Analyze and track the use of our Services;

12.2.5. Adjust our Platform according to Your trading habits and our regulatory requirements.

12.3. KoinBay uses the following Cookies to operate the Platform

12.3.1. Essential Cookies are known as strictly necessary Cookies for You to browse our Platform and use its features, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from You. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed.

12.3.2. Session Cookies are temporary and expire once You close Your browser. It stores information for the time, or session when You are on our Platform.

12.3.3. First-party cookies are placed on Your device directly by the Platform You are visiting.

12.3.4. Third-party cookies are placed on Your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests, and then customize advertising the User on other websites. Any information obtained from Third-Party Cookies is processed by the respective collaborative partners.

12.3.5. Persistent Cookies encompass all Cookies that remain on Your hard drive until You erase them or Your browser does it which depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary.

12.3.6. Google Analytics Cookies to measure our User’s interactions with the content on our Platform. These Cookies collect information about Your interactions with our Platform, such as unique visits, repeat visits, session duration, and Platform activity.

12.3.7. Functionality Cookies allow our Platform to remember choices You have made in the past like what language You prefer, what region You would like, or what username and password are so You can automatically log in. We use Cookies for navigation and to facilitate Your access to and use of this site. These Cookies are necessary for the transmission of communications on the network or to supply services whatever requested by You. Further, they help us to know which pages are the most and least popular and see how visitors move around the website.

12.3.8. Performance Cookies collect information about how You use our Platform, like which page You visited and which link You clicked on. None of this type of information can be used to identify You. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit.

12.3.9. Marketing Cookies track Your online activity to help advertisers deliver more relevant advertising or to limit how many times You see an ad. These Cookies can share information with other organizations or advertisers. However, these are Persistent Cookies which are third-party-proven. These cookies may be set through the website by our advertising partners. If You do not allow these cookies, You will experience less targeted advertising.

12.4. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise Your Cookie rights by setting Your preferences when accessing our website. However, You will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide You with our Services. In the event You choose to reject certain Cookies, You may still use our Platform though Your access to some functionality and areas of our Platform may be restricted. You may also set or amend Your web browser controls to accept or refuse Cookies.


13.1. KoinBay reserves the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time indicating the date on which the latest changes were published at the top of this page.

13.2. Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. KoinBay encourages You to regularly visit our Platform to stay informed about any changes to these Policies and the Terms.

13.3. Your continued access to the Platform means that You agree to the updated content and to abide by the updated Policy.

13.4. The most updated version of this Policy is available at

13.5. Any differences between this Policy and the Terms and Conditions, the former Terms and Conditions prevail.


14.1. In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns at

Last updated