Privacy Policy

1. The Scope

This policy outlines the types of personal data the Company collects from individuals, how we process and share it with third parties, and the security measures we apply.

This Policy addresses 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 reasonably access.

Section 1.3 defines "processing" as any activity involving the collection or use of Personal Data, including its management, structuring, and storage.

Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect information from anyone under 18 or permit them to use our services. If we discover that we have collected information about a minor, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our service, channels, or website, we collect Personal Data. We may also request additional Personal Data from you in specific situations.

We also collect your Personal Data when you use our Services, through our service channels, or from third-party partners who share information with us.

3. No Requirement to Disclose Personal Information

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

4. What Personal Data We Collect

The information you collect is not personal information and cannot identify you.

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

When you provide personal information to third-party platforms to facilitate trading, 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 for the purposes outlined in this section and in accordance with the applicable legal basis.

For more details about how we process your information to protect legitimate interests, please contact us by email.

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

6. Transfer of Personal Data to Third Party

The Company shares Personal Data with third-party service providers, including hosting, storage, and analytics partners, to support site operations and improve user experience.

You can request that we share your Personal Data with specific 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, and your data may be shared with multiple platforms.

We may share your Personal Data with affiliated entities and business partners to enhance and improve our products and services.

We may disclose your Personal Data to 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 other company in our group if such a transaction takes place—including the transfer or sale of Company assets or assets of any group company—or in connection with any 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, such as advertising partners and analytics providers, on our website. These companies may use cookies or similar tracking technologies to collect information.

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 customize the products and services we offer. Cookies also help us gather statistics and analytics data.

We use two types of cookies. 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, allowing you to resume your experience more quickly.

Be aware that certain features or the entire Website's functions may not work as expected if this occurs.

Online Tracking Notice: This service does not currently support do-not-track signals.

8. Retention of Personal Data

We retain 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 lawful orders.

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

We regularly review the Personal Data we hold to confirm it is no longer needed.

9. International Transfers

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

We can explain the security measures we use to protect your Personal Data when it is transferred to third parties or international organisations. For details, please 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 measures against accidental or unlawful destruction, loss, or alteration.

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

In the event of legal or regulatory obligations beyond our control, we may be required to disclose your Personal Data to third parties, including public authorities. We cannot guarantee the security measures applied to your Personal Data once transferred to these third parties.

Internet data transmission cannot be guaranteed completely secure. We cannot ensure the security of Personal Data you transmit to us online.

11. Hyperlinks to Third Party Websites

The Company does not supervise third-party sites and applications linked on this website. We are not responsible for how these sites or apps collect or process your Personal Data. This Policy does not apply to your use of third-party sites or apps.

When you access third-party websites or apps, review their privacy policies before deciding whether to use them. Consider carefully what Personal Data you share with these services.

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 can review the changes.

When we make significant changes to this Policy, we will notify you through appropriate channels and post 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. You may also limit how we process your personal information.

If you are an EEA resident, please refer to this page for information about your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access Rights The Company can verify the accuracy of Personal Data being processed about you. If your Personal Data is being processed, you have the right to access it. The Company will provide an electronic copy of your Personal Data at no charge. Additional copies may be subject to a reasonable fee. Data will be made available electronically upon request. The right to access Personal Data cannot override the rights and freedoms of others. If granting access would harm another person's rights or freedoms, the Company may refuse the request or limit the information disclosed.

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, taking into account the purpose for processing.

13.5 Right to Erasure You may request erasure of your Personal Data in the following circumstances: (a) The Personal Data are no longer necessary for the purposes for which they were collected or processed; (b) You withdraw your consent and no other legal basis exists 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 Personal Data are processed unlawfully; (e) The Personal Data must be deleted 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 claims.

13.6 Processing Restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company limit its processing. When Personal Data is restricted, it may only be retained if you provide consent, or if it is necessary to establish, exercise, or defend legal rights—either your own or those of another individual—or where there is a significant 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 your Personal Data. You may request that the Company transfer your Personal Data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your other rights, including your right to erasure. Your right to data portability 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 objection to profiling based on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may only continue processing if we can show that our interests outweigh your rights, freedoms, and interests, or if processing is necessary to establish, exercise, or defend legal claims. Regarding Direct Marketing You 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 will not affect the lawfulness of any processing that occurred based on your consent before you withdrew it. You have the right to lodge a complaint with your local supervisory authority. Within the European Union, you may appeal to your Member State's supervisory authority, which is responsible for protecting individual rights in relation to Personal Data processing. EU and Member State laws may limit your rights regarding your Personal Data, as described in this section 13.

We will provide you with the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. If needed, we may extend this timeframe to up to two months depending on the nature and volume of your request. We will notify you of any extension and the reasons for it within one month of receiving your request.

Provided that it does not conflict with section 13 of the law, we will provide information you request under your section 13 rights at no cost. If your request is frivolous, excessive, or repetitive, we may charge a reasonable fee to cover our administrative costs for processing the information or taking the action you have requested. We may also decline to proceed.

If we have concerns about who actually submitted your request, we may ask you to provide reasonable verification of your identity.