Privacy Policy

1. The Scope

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

This Policy applies to information about you as an identified or identifiable natural person. You are identifiable either directly or through a combination of information we hold or can access.

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

Our services are intended for general audiences and not 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 data from someone under 18, we will delete it promptly.

2. What Personal Data Do We Have on You

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

We also collect your Personal Data by monitoring how you interact with our Services and platforms, and by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide Us with any Personal Data. However, if you choose not to supply certain Personal Data, We may be unable to offer the Services or allow you to access the website.

4. What Personal Data We Collect

The information collected through this section is not personal data and cannot be used to identify you.

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

When you share information with third-party platforms to complete a trade, this 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 in accordance with the purposes and legal basis set out in this section.

For more details on how we process information to protect legitimate interests, please reach out to us via email.

5.4 We may use the information you provide for the following reasons and legal grounds:

6. Transfer of Personal Data to Third Party

We may share your Personal Data with third-party service providers—such as hosting, storage, and analytics providers—to help us operate our platform and understand how you use it, including through IP address information and user experience analysis.

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. How they use your information is governed by their privacy policies, not ours. Your Personal Data may be shared with multiple trading platforms.

We may share your Personal Data with affiliated entities and business partners to obtain resources that help us enhance our products and services.

We may share your Personal Data with regulatory, local, or other official authorities when necessary to protect the rights of third parties or safeguard assets.

We may share your Personal Data with potential investors, buyers, or lenders to the Company or any group company in connection with a transaction—including the transfer or sale of Company assets or any group company assets—or as part of a merger, restructuring, consolidation, or bankruptcy involving the Company or any group company.

7. Cookies and Services from Third Parties

We may use third-party services, including advertising and analytics providers, which may use cookies or similar 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 the products and services we offer. Cookies also help us gather usage statistics and analytics data.

We use two types of cookies on this website. Session cookies are temporary and are deleted when you close your browser. Persistent cookies remain on your device after you close your browser, allowing us to recognize you as a returning user and provide a seamless experience when you return to the website.

Be aware that certain features or the entire Website's functionality might not work as expected in these circumstances.

Online Tracking Notice: We do not currently honor do-not-track signals on this service.

8. Retention of Personal Data

The Company retains your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as 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 thereafter.

We regularly review Personal Data we hold to confirm it's no longer needed.

9. International Transfers

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

If you need details about the security measures we use to protect your Personal Data when transferred to third countries or international organisations, contact us at support@clutoor-toorn.best.

10. Security of Personal Data

We maintain appropriate organizational and technical safeguards to protect your Personal Data, including protection against accidental or unlawful destruction, loss, or alteration.

While we implement security measures to protect your Personal Data, we cannot guarantee absolute protection against all risks. We are not liable for indirect, incidental, or consequential damages resulting from the use or disclosure of your Personal Data, including losses arising from transmission errors, unauthorised third-party access, or circumstances beyond our control.

When we are required by law or other circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we must do so. We cannot guarantee the level of security those third parties apply to your data once it is in their possession.

Internet data transmission cannot be fully secured. We cannot guarantee the security of Personal Data you send to us online.

11. Hyperlinks to Third Party Websites

The website includes links to third-party sites and applications that operate independently of the Company. We do not control these external platforms and are not responsible for how they collect or process your personal data. This Privacy Policy does not apply to your activity on third-party sites or applications.

When visiting any third-party website or app, review their privacy policies before deciding to use them. Consider the implications before sharing your 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 so you are informed of any 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 take effect upon publication of the revised Policy unless otherwise specified.

13. Your Rights

You have the right to request verification of the accuracy of Personal Data collected about you, to correct any inaccuracies, and to delete Personal Data we no longer need. You may also limit how your Personal Data is processed.

If you are an EEA resident, please refer to this page for information about your data rights. You may exercise these rights with respect to your Personal Data by contacting us at the email address below.

13.3 Access Rights The Company can verify the accuracy of Personal Data being processed about you. If accurate, 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 charge, though a reasonable fee may apply for additional copies. Data will be delivered electronically upon request. Your right to access Personal Data cannot override 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 compliance with it.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request correction of any incomplete or inaccurate Personal Data concerning you, based on the purpose of processing.

13.5 Right to Erasure You may request that we delete your personal data in the following circumstances: (a) The data is no longer necessary for the purpose for which it was collected or processed; (b) You withdraw your consent and there is no other legal basis for processing; (c) You object to processing based on legitimate interests pursued by us or a third party, for reasons specific to your situation; (d) The data has been processed unlawfully; or (e) The data must be deleted to comply with a legal obligation. This right does not apply when processing is necessary to fulfill a legal obligation under European Union or Member State law, or to establish, exercise, or defend legal claims.

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

13.7 Right to data portability If your personal data is processed by an automated system and this processing is based on your consent or a contract you are party to, you have the right to access and review the personal data you have provided to 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 the right to erasure. Your right to data portability does not interfere with the rights or freedoms of others.

13.8 Right to Challenge You may 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 processing solely for profiling based on such legitimate interests. If we have established compelling legitimate grounds for processing your Personal Data, we may continue only if we can demonstrate that those grounds outweigh your rights, freedoms, and interests, or the establishment, exercise, or defense of legal rights. You also have the right to object to processing of your Personal Data for direct marketing purposes at any time.

13.9 Right to Refuse Consent 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 you withdrew your consent. You have the right to lodge a complaint with the supervisory authority in your jurisdiction. If you are in the European Union, you may appeal to the data protection authority established by your member state to protect your fundamental rights regarding Personal Data processing. EU law and member state laws may limit your rights concerning your Personal Data, as detailed in this section 13.

We will provide you with the requested information within one month of receiving your request. If the nature or volume of your request requires additional time, we may extend this deadline to two months. We will notify you of any extension and the reasons for it within one month of receipt.

As long as it does not contradict section 13 of the law, information you request under your rights in section 13 will be provided at no cost. If your request is unjustified or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on such requests.

If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable identification.