Privacy Policy

1. The Scope

This policy outlines the Personal Data we collect from individuals and how we process, share, and protect it.

This Policy addresses information relating 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 reasonably access.

"Processing" refers to any operation involving the collection, use, management, structuring, or storage of Personal Data.

1.4 Our services are intended for general audiences and are not designed for users under 18 years old. We do not knowingly collect information from anyone under 18, nor do we permit such individuals to use our services. If we become aware of information about minors, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our service, channels, or website, we collect your Personal Data. We may also request your Personal Data at certain points in your interaction with us.

In some cases, we collect your Personal Data by monitoring how you use our Services, through our service channels, or from information shared by our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide Us with personal Data. However, in certain circumstances, failing to supply necessary information may prevent Us from delivering the Services or allow you to access the website.

4. What Personal Data We Collect

The information collected does not identify you personally and is not considered private information.

Personal data you provide when you connect with a third-party online trading platform through us.

Personal information you provide to third-party platforms to facilitate trade includes 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 described in this section and in accordance with the applicable legal basis.

For details on how we protect your legitimate interests, please contact us via email.

# Here is the rewritten text: 5.4 Below are the legal grounds we use to process the information you provide:

6. Transfer of Personal Data to Third Party

The Company may share your Personal Data with third-party service providers, including hosting, storage, and analytics partners, who process IP address information and analyze user experience data on our behalf.

You can request that we share your Personal Data with third-party trading platforms. We will provide the Personal Data you share with us to these platforms in accordance with their privacy policies. Your Personal Data may be shared with multiple trading platforms.

We may share Personal Data with related entities and business partners to enhance and improve the products and services we provide to customers.

6.4 Data Disclosure to Protect Third-Party Rights and Assets The Company may disclose Personal Data to regulatory authorities, government agencies, or other official bodies when necessary to safeguard the rights of third parties or protect assets.

We may share your Personal Data with potential investors, buyers, or lenders to the Company or other group companies in connection with a transaction (including asset transfer or sale) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or another group business.

7. Cookies and Services from Third Parties

We use third-party services—including advertising partners and analytics providers—which 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 personalize the products and services we offer. Cookies also help us gather analytics and usage data.

7.3 We use two types of cookies. Session cookies are temporary and deleted 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, allowing you to return to the website more easily.

However, be aware that certain functions or the entire Website's features may not work as expected in these circumstances.

Online Tracking Notice: This service does not support 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 for longer periods as required by applicable law, regulation, 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.

9.3 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@clauvic-torun.best

10. Security of Personal Data

We implement appropriate organizational and technical safeguards to protect your Personal Data, including measures against 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 arising from the use or disclosure of your Personal Data, including (but not limited to) disclosure due to transmission errors, unauthorised third-party access, or other causes beyond our control.

If we are required by law or other circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we will do so. However, we cannot guarantee the security measures those third parties apply to your data.

# Section 10.4: Data Transmission Security Personal data cannot be transmitted over the internet with complete safety. 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 from our site operate independently and are not under our control. 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 sites or apps.

11.2 When you access any third-party websites or apps, we recommend that you review their privacy policies before using them. We also recommend that you exercise caution before sharing any Personal Data with them.

12. Modifications to This Policy

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

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

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

13. Your Rights

You have the right to request that we verify the accuracy of Personal Data we collect about you, correct any inaccuracies, and delete Personal Data we no longer need to retain. You may also limit how your personal information is processed.

If you are a resident of the EEA, please refer to this page for your data rights. You have certain rights regarding your Personal Data. To request to exercise these rights, contact us by email at the address below.

13.3 Access rights The Company can verify the accuracy of your Personal Data and confirm whether it is being processed. If it is, you have the right to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed at no cost; additional copies may be subject to a reasonable fee. Data will be supplied electronically upon request. Your right to access Personal Data must not infringe the rights and freedoms of others. The Company may refuse a request or limit its scope if granting it would be detrimental to the rights and freedoms of another person.

13.4 Right to rectification We may correct inaccurate Personal Data in our records. You have the right to request that incomplete or inaccurate Personal Data be corrected, based on the purpose of processing.

13.5 Right to Erasure We will erase your Personal Data in the following circumstances: (a) The data is no longer necessary for the purpose it was collected for; (b) You withdraw consent and no legal basis exists to continue processing; (c) You object to processing based on your particular circumstances, where the processing relies on legitimate interests pursued by us or a third party; (d) The data has been processed unlawfully; or (e) We are required by law to delete the data. This right does not apply when processing is necessary to: (a) Fulfill a legal obligation under European Union or Member State law; or (b) Establish, exercise, or defend legal rights.

13.6 Processing Restrictions You may request that the Company limit the processing of your Personal Data if you have concerns about its accuracy. When Personal Data is restricted, it may only be retained if you consent to its retention, or if it is necessary to establish, exercise, or defend legal rights—either your own or those of another individual—or if there is a reason of substantial public interest within the European Union or a Member State.

13.7 Right to data portability When processing is carried out by automated systems and is based on your consent or a contract involving you, you have the legal right to access your Personal Data held by 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 rights under data erasure. The transfer of your data does not interfere with the rights or freedoms of others.

13.8 Right to Challenge You have the right to object to any processing of your Personal Data based on legitimate interests pursued by the Company or a third party at any time. This includes objections to profiling based on those legitimate interests. We will stop processing your Personal Data only if you demonstrate that your rights, freedoms, or interests outweigh our legitimate grounds, or if processing would interfere with the establishment or defense of legal claims. Regarding direct marketing, you may object to the processing of your Personal Data concerning you at any time.

13.9 **Right to Refuse Consent** You may revoke your consent for us to process your Personal Data at any time. Revoking consent does not affect the lawfulness of any processing completed before withdrawal. You have the right to lodge a complaint with your local supervisory authority. If you are in the European Union, you may appeal to the data protection authority in your member state, which safeguards fundamental rights in Personal Data processing. EU law and member state laws may limit your rights regarding your Personal Data, as outlined in this section 13.

We will provide you with the information you request under Section 13 of this agreement within one month of receiving your request. If needed, we may extend this period to two months depending on the complexity and volume of your request. We will notify you of any extension and the reasons for it within one month of receiving your request.

Information you request under section 13 will be provided free of cost, provided the request complies with section 13 of the law. If your request is unjustified, excessive, or repetitive, we may charge a reasonable fee to cover administrative costs. We may also decline to act on such requests.

If we have doubts about your identity, we may ask you to provide reasonable means of identifying yourself.