Privacy Policy

1. The Scope

This policy explains what personal data we collect about individuals, how we process and share it with third parties, and how we protect it.

This Policy covers information related to an identified or identifiable natural person. An identifiable natural person is one who can be directly identified or recognized through a combination of information we hold or can access.

1.3 The Policy defines "processing" as any activity involving the collection or use of Personal Data. This includes organizing, structuring, and storing Personal Data.

1.4 Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect information from minors or permit them to use our services. If we become aware of any information about a child, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our services, channels, or website, we collect Personal Data. We may also request Personal Data from you in certain circumstances.

In some cases, we collect your Personal Data by monitoring your use of our Services, analyzing interactions across our service channels, or receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide personal data. However, without certain information, we may be unable to deliver our Services or allow you to access the website.

4. What Personal Data We Collect

The information we collect does not personally identify you and cannot be used to identify your identity.

Personal data you provide directly when connecting to a third-party online trading platform through us.

When you provide information to third-party platforms to facilitate trade, we collect your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

Your personal data is processed by the company for the purposes set out in this section and in accordance with the applicable legal basis.

For questions about how we protect your legitimate interests, please contact us via email.

Below is a list of the reasons and legal grounds we may use the information you provide:

6. Transfer of Personal Data to Third Party

We may share your Personal Data with third-party service providers, including hosting, storage, and analytics companies, who help us operate our platform and understand user experience. These providers may receive your IP address information as part of these services.

You can request that we share your Personal Data with third-party trading platforms. When you do, we will provide your Personal Data to those platforms. Their use of your information is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.

The Company may share Personal Data with related entities or business partners to enhance and improve the products and services it provides to its customers.

When we need to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

We may share your Personal Data with potential investors, buyers, or lenders to us or any group company in connection with a proposed transaction—including asset transfer, sale, merger, restructuring, consolidation, or bankruptcy of our company or any group company.

7. Cookies and Services from Third Parties

We use third-party services such as advertising providers and analytics companies. These services may use cookies or similar tracking technologies on our website.

Cookies are small text files stored on your device when you visit our website. We use them to understand your preferences and browsing behavior, improve your experience, remember your settings, and tailor content and services to your interests. Cookies also help us gather analytics and usage statistics.

7.3 We use two types of cookies on this website. Session cookies are temporary and expire when you close your browser. Persistent cookies remain on your device after you close your browser and help us recognize you as a returning user, enabling a seamless experience when you visit again.

Be aware that certain features or the entire Website may not function as expected in these circumstances.

Online Tracking Notice: This service does not respond to do-not-track signals.

8. Retention of Personal Data

We retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or as otherwise permitted by applicable law, regulations, and court orders.

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.

We regularly review the Personal Data we retain to ensure it is no longer necessary.

9. International Transfers

Your personal data may be transferred to other countries or to international organizations. We implement appropriate safeguards to protect your personal data and ensure you can exercise your rights and access effective legal remedies.

We can provide details about the security measures we use to protect your Personal Data when it is transferred to third-party countries or international organisations. Contact us at support@clufoth-torn.best for more information.

10. Security of Personal Data

We have implemented appropriate organizational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your Personal Data will remain secure without error. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of your Personal Data, including disclosure due to transmission errors, unauthorized third-party access, or any other cause beyond our control.

When we are required by law or circumstances beyond our control to disclose your Personal Data to third parties such as public authorities, we cannot guarantee the level of security those parties will provide to your information.

Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of personal data you send to us online.

11. Hyperlinks to Third Party Websites

Third-party websites and applications linked on our site operate independently and are not supervised by the Company. We are not responsible for how these sites or apps collect or process your Personal Data. This Policy does not apply to your activity on third-party platforms.

When you visit third-party websites or apps, review their privacy policies before accessing or using them. Be cautious about providing any Personal Data to third parties.

12. Modifications to This Policy

We may update this Policy at any time. When we do, we will post the updated Policy on our website to notify you of the changes.

When we make significant changes to this Policy, we will notify you using appropriate methods and publish an announcement on our website.

Any amendments will become effective upon publication of the revised Policy unless explicitly stated otherwise.

13. Your Rights

You are entitled to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete Personal Data we no longer need to retain. You may also restrict the types of processing applied to your Personal Data.

If you are an EEA resident, please refer to this page for your data rights. You have rights regarding the personal data you provide to us. To exercise these rights, send an email to the address below.

13.3 Access Rights The Company can verify the accuracy of your Personal Data being processed. If accurate, you have the right to access your Personal Data. The Company will provide an electronic copy of your Personal Data at no charge. Additional copies may be provided for a reasonable fee. Data will be made available electronically upon request. Your right to access Personal Data must not conflict with the rights and freedoms of others. If your request would harm another person's rights or freedoms, the Company may refuse the request or limit its scope.

Your right to accurate and complete Personal Data is protected. We may correct inaccurate Personal Data in our records. You may request that we rectify any incomplete or inaccurate Personal Data about you, taking into account why we process it.

Your right to request erasure of your personal data applies when: (a) Personal data are no longer necessary for the purpose for which they were collected or processed; (b) You withdraw consent and no legal basis for processing exists; (c) You object to processing of your personal data based on legitimate interests pursued by us or a third party, for reasons specific to your situation; (d) Personal data are processed unlawfully; or (e) Personal data must be removed to comply with a legal obligation. This right does not apply when processing is necessary to: (a) Fulfill a legal obligation required under European Union law or Member State law; or (b) Establish, exercise, or defend legal rights.

13.6 Processing Restrictions If you believe your Personal Data is inaccurate, you may request that the Company limit its processing. When Personal Data is restricted, it may only be retained if you provide consent, or to establish, exercise, or defend legal rights—either your own or those of another individual—or when required by significant public interest within the European Union or a Member State.

Your right to data portability If your Personal Data is processed by an automated system and the processing is based on your consent or a contract to which you are a party, you have the legal right to obtain and review your Personal Data from the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure or the rights and freedoms of any other person.

Right to Challenge You have the right to object to any processing of your Personal Data based on the Company's or a third party's legitimate interests at any time. This includes objection to profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing, we may continue only if those grounds outweigh your rights, freedoms, and interests, or if processing is necessary to establish, exercise, or defend legal claims. Regarding direct marketing, you may object to the processing of your Personal Data at any time.

You may revoke your consent for us to process your Personal Data at any time. This does not affect the legality of any processing that occurred before your consent was withdrawn. You have the right to lodge a complaint with your supervisory authority. If you are in the European Union, you may appeal to a supervisory authority established by a member state to protect fundamental rights in relation to Personal Data processing. EU and member state laws may limit your rights regarding your Personal Data as outlined in this section.

Within one month of receiving your request, we will provide the information you are entitled to under section 13 of this agreement. We may extend this timeframe to two months if the complexity or volume of your request requires it. If an extension is necessary, we will notify you within one month of receiving your request and explain the reason for the delay.

13.11 Requests for information under section 13 will be provided free of charge, provided they comply with section 13 of the law. If a request is unjustified, excessive, or repetitive, we may charge a reasonable administrative fee to cover our costs in providing the information or taking the requested action. We may also decline to proceed.

If we have doubts about the identity of the person who submitted your request, we may ask you to provide reasonable means of identifying yourself.