Privacy Policy

Cedar Privacy Policy

‍[Last Updated: September 6, 2023]

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MBD Financial Ltd., a company organized under the laws of the United Kingdom (“Cedar”, “our”, “we” or “us”), is the owner, developer and operator of an online platform enabling the collecting, storing, processing and communicating of Client Instructions and other information to, from and among Client, Members and Cedar (collectively "Services").

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This Privacy Policy (“Privacy Policy”), constitutes an integral part of our Cedar Client Terms of Service ("Terms"), and it governs how Cedar collects, uses and discloses certain information, including Personal Data (as defined below). This Privacy Policy is meant to help you understand what information we collect, why we collect it, how we safeguard it and how you can control it by exercising the rights granted to you by applicable data protection laws. Definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.

Applicability: This Privacy Policy applies where a Member or a Client is accessing to and using the Services, or merely when an individual is visiting or engaging with our website ("Visitor") available at https://www.cedar.money/ ("Website"). Each a Member, Client and Visitor shall be also be referred as "you"

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING OUR SERVICES AND WEBSITE. BY ACCESSING OR USING OUR SERVICES OR WEBSITE YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES OR THE WEBSITE.

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Data Controller

MBD Financial Ltd., incorporated under the laws of the State of the United Kingdom, is the ”Data Controller” (as such term is defined privacy legislation) of the Personal Data collected from Visitors Clients and Members.

If you have any question, inquiry, request or concern related to this Privacy Policy or the processing of your Personal Data, you may contact us, and our privacy team at: privacy@cedar.money

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The Data We Collect & Our Lawful Basis for Processing Your Personal Data

Depending on your interaction with us, meaning if you browse our website, we collect two types of data:

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"Non-Personal Data" meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the website, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our website, language preference, and other technical information regarding the device used to access the website, for example type of device, type of browser, operating system, etc. This data is considered as Non-Personal Data when collected on an aggregate basis, or otherwise not combined with online identifiers.

Also, we may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, in order to maintain and develop our website, including among others, for ensuring the technical functioning of our website, to help prevent fraudulent use of the website, etc.

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"Personal Data" meaning, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual. This may include online identifiers, first and last name, email address, etc.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

We have included in the table below information about the types of Personal Data processed, how we process and use Personal Data, the lawful basis for which we do so subject to the GDPR and processing operations.

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Type of Data

Purpose of Processing & Operation

Lawful Basis

Device Identifiers and Online Usage

When you interact with the website, we may collect online identifiers such as your Internet Protocol address (“IP”), Cookie-ID, etc., as well as other information that relates to your activity through the website, such as pages viewed, click stream data, login time and date stamp, etc. This data might be collected directly by us or by through our use of third parties' cookies.

Collection of device identifiers is needed for the following purposes:

(i) Website’s operation, security and fraud detection purposes, and for example, when you fill in a form on our website, in order to detect and prevent malicious attacks;

(ii) Internal statistics and analysis, for which device identifiers might be combined with usage data, for example, to analyze how many Visitors have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content;

(iii) Marketing and advertising purposes.

Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address.

Our lawful basis for the processing this data for operation and security purpose is based on our legitimate interests.

Where required under applicable laws, we will obtain your consent for the purpose of data collection through our use of third-party cookies for analytics purposes and marketing purposes. In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our website.

Contact Communications

If you are a Member or if voluntarily contact us through any means of communication, we make available (e.g., send us an email, or use any other online form available on our website), you will be requested to provide us with your contact information such as your name, phone number and email address.

We process your contact information solely for the purpose of contacting you, responding to your inquiries and provide you with the support or information you have requested.

The correspondence with you may be processed and stored by us in order to improve our internal operation, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with us.

We process such data subject to our legitimate interest.

Newsletter & Updates Registration

In the event you sign up to receive our newsletter or other promotional materials, you will be requested to provide your contact details, such as email address.

We will use the information you provide in order to include you in our mailing list and send you the materials you have signed up to receive.

Our lawful basis for the processing of this data is your consent.

You may withdraw your consent at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us through the above means of contact and request to unsubscribe.

Know Your Client and Account Information

When a Client register to our services, such Client's key personnel (i.e. authorized signatories, directors and Ultimate Beneficial Owner) will be asked to submit certain information as part of the know your client process (KYC) such as: full name, email address, telephone number, IDs, utility bills and any other information requested to complete the KYC process

In addition we will use your email and name as part of the signing up process and to create your account ("KYC and Account Information").

We use the KYC and Account Information to register you to our services, create your account, authentication, provide account management (including billing and invoices), customer support and to provide the Services.

In addition, we use your email address in order to provide you with marketing related communication such as new features, additional offerings, special opportunities or any other information we think our Customers will find valuable (“Direct Marketing”).

We process your KYC and Account Information for the performance of our contract with you or, depending on your interaction with us, in order to take steps prior to entering into such contract.

Where we use you email address for direct marketing purposes, such processing is subject to our legitimate interest. Note you can opt-out at any time from Direct Marketing through the “unsubscribe” link within the emails we send you. Note however that if you choose to opt-out from Direct Marketing, we will further maintain a suppression file – meaning lists of applicable email addresses that have requested to opt-out, under our legitimate interest and to ensure we comply with such preference and choice.

Usage Data:

When you use the App, information regarding such use is automatically generated and collected, which may include the click stream within the Platform, the time spent on each page or feature, crash data and analytics, how often you use the Service etc. ("Usage Data").

We use your Usage Data to help us understand how you are using our Services, and how to better provide and improve our Services to you. This helps us to better understand our business, analyse our operations, maintain, improve, innovate, plan, design, and develop the Service and App. We also use your Usage Data for statistical analysis purposes, to test and improve our Services, decide how to improve the Service based on the results obtained from this processing.

We process your Usage Data subject to our legitimate interest.

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How We Collect Information

Depending on the nature of your interaction with us through the website, we may collect information as follows:

Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agent, etc.) to gather some information automatically.
Provided by you or about you voluntarily – we will collect information if and when you choose to provide us with the information, for example, when you register and create an account or correspond with us.

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Cookies

When you access or use the website, we use “cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here:www.allaboutcookies.org.

There are several types of cookies, and among others:

Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling Visitor movement around the website, for the website to function properly, and for security purposes (i.e., used to authenticate Visitors, prevent fraudulent use, and protect Visitor data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.
Analytic, Measurement & Performance Cookies. These cookies are used to collect information about how Visitors use our website, in order to improve our website, content, and the way we offer them, as well assess performance of the content and marketing campaigns. These cookies enable us, for example, to assess the number of Visitors who have viewed a certain age as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.
Preference, Targeting & Advertising Cookies. These cookies are used to advertise across the internet and to display relevant ads tailored to Visitors based on the parts of the website they have (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage)

You may find more information about the cookies we use as well as opt-out of cookies or change your preferences and any time by using the cookies setting tool available on our website.

Also note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly, and your online experience may be limited.

Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies and we are not responsible for their privacy practices.

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Data Sharing – Categories of Recipients We Share Personal Data With

We share your Personal Data with third parties, including with trusted partners or service providers that help us to manage our business operation, website, etc. You can find here information about the categories of such third-party recipients.

Category of Reipient	Data That Will Be Shared	Purpose of Sharing
Members	KYC and Account Information	We will share the KYC and Account Information with applicable Members in order to provide our Services and able the transfer of the funds requested by you to such or with the assistance of such Members
Service Providers	All types of Personal Data	We employ other companies and individuals to perform functions on our behalf, such as sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Any acquirer of our business	All types of Personal Data	We may share all types of Personal Data in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In such event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Enforcement of our rights and security detections.	All types of Personal Data	We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
Legal and law enforcement	Subject to law enforcement authority request.	We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of the Company, our Customers, or others.

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Where we share Personal Data with services providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services of fulfil the purpose for which data was shared. These parties are required to secure the Personal Data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with applicable data protection regulations (note that, such service providers may use other Non-Personal Data for their own benefit).

Cross-Border Data Transfer

Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries. Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. Where Personal Data collected from within the EU or UK, is being transferred outside such territories to countries which didn’t receive an adequacy decision on behalf of an authorized authority (such as the EU Commission), we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union or the UK Information Commissioner’s Office . Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.

In addition, some of the third parties used for cookies management in our website, may store and process data globally, including in the US (e.g., Google Analytics servers). When granting consent for such cookies through the cookies tool in the website, you hereby acknowledge and approve such cross border transfer, in accordance with such third party’s privacy practices.

Data Retention

We retain the Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:

Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;
Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges; or
If we reasonably believe there is a prospect of litigation relating to your Personal Data.

We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

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Privacy Rights

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data. Depending on your relationship with us (e.g., if you are a visitor of our website or a Visitor), your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

For detailed information on your rights and how to exercise your rights, please fill the data subject form accessible from here and send it to our privacy team at: privacy@cedar.money

Certain rights can be easily executed independently by you without the need to contact us, and for example:

You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
You can use the cookie settings tool on our website to change your preferences.

Where we are not able to provide you with the information for which you have asked, we will endeavour to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

Security

We take great care in implementing and maintaining the security of our website Visitors’ Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such.

We have implemented technical, physical and administrative security measures to protect the Personal Data we process. In addition, we limit access to Personal Data stored by us.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@cedar.money, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

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‍Children’s Data

The website is not intended for individuals under the age of eighteen (18). Accordingly, we do not knowingly solicit Personal Data from or market to children as defined under applicable law. We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed herein.

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Changes and Updates

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this Privacy Policy, we will make reasonable efforts to post a clear notice on the website, and obtain your consent where required under applicable. Changes to this Privacy Policy are effective as of the stated “Last Updated” date and your continued thereafter will constitute acceptance of, and agreement to be bound by, those changes.

USA 405 Cameron Sreet, Alexandria, Virginia, 22314

50 W 23rd Street,
New York, 10010

UK c/o FKGB, 2nd Floor, 201 Harverstock Hill, London, NW3 4QG

Nigeria7 Ibiyinka Olorunbe Street Victoria Island Lagos, Nigeria

Israel Derech Menachem Begin 150, Tel Aviv-Yafo, 6592105

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Please note: Cedar does not hold or transmit any funds and does not hold MSB or money remittance licenses.‍