Privacy Notice

Cumberland DRW LLC and its affiliated companies (collectively, “Cumberland”, “we”, “us”, or “our”), are committed to transparency in the collection and use of your personal information.

This notice (the “Privacy Notice”) sets forth a description of how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Notice also describes your data protection rights and how you may exercise them, as set out below.

This Privacy Notice applies to all visitors to Cumberland’s website, located at https://cumberland.io/ (the “Website”).

California residents, please review the California Privacy Notice for information about your rights under California’s privacy laws.

Collection and Use of Information

Cumberland may collect and use personal information, such as your name, address, email address, signature, and other information, in connection with the following:

Visiting our Website;
Applying to onboard with us;
Communicating with us (e.g., contacting us with a comment, question, or complaint);
Safety and security; and
Complying with applicable laws and regulations.

Onboarding Information: To onboard as a counterparty through our Website or through other means, we may require you to provide us with certain personal information, including, but not limited to, your full name, email address, residential address, birth date, phone number, country of residence and nationality, employment information and status, national and governmental identification information, and financial and banking details, including any joint account holders and people appointed to act on your behalf. Cumberland uses this information to undertake anti-money laundering and fraud prevention activities and know your customer reviews.

If you do not provide required personal information, it may mean that we are unable to onboard you or provide you with services and perform all of our obligations under our agreement(s) with you.

If you provide us the personal information of other persons (such as joint account holders), you confirm that they are aware of the information in this Privacy Notice concerning how we will use their personal information, including, but not limited to, use of their personal information to provide services and our disclosure of personal information to third parties (e.g., to provide payment initiation).

Once you have been onboarded as a counterparty, Cumberland will continue to use this information as necessary to effect transactions with you.

We may also obtain information about you from other sources, including identity verification services, fraud prevention agencies, websites and other publicly accessible information. We will also receive data you submit to us through third-party websites.

Communications: You may request to receive communications about Cumberland through our Website or connect with us on third party websites (including through social media sites). If you sign up through our Website or request to receive communications from us, we collect certain personal information (such as first and last name and email address) which we use to send you email and other communications to keep you informed about our events and to tell you about services that may be of interest to you.

Contact Information: When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, phone number, and email address) along with additional information we need to help us answer your question or respond to your comment or complaint.

Social Media Information: If you interact with us through social media or other channels, we may store the details of these interactions.

Automatically-Collected Information: We may collect the IP (Internet Protocol) addresses of visitors to our Website and other related information, such as page requests, browser type, operating system, average time spent on our Website, and how you are using our Website. We use this information to help us understand activity on our Website and to monitor and improve our Website. We may also collect information from your digital devices to perform checks required to meet our regulatory obligations; for example, we may identify your IP address in order to ascertain and verify your residency status.

Information Collected with Consent: Where your consent is required by law, we may seek to obtain your consent to collect and use certain types of personal information. If we ask for your consent to process this personal information, you may have the right to withdraw your consent.