Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, and how it processes, shares with third parties, and secures that data.

1.2 This Policy applies to information relating to an identified or identifiable natural person. A natural person is considered identifiable if they can be identified directly or through a combination of additional information we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" means any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not available to anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we permit them to use our services. If we become aware that any such information has been collected, 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. In certain instances, we may request specific personal data from you.

2.2 We also collect your personal data by analysing how our Services and service channels are used, or by receiving your information from third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering the Services or restrict your access to the website.

4. What Personal Data We Collect

The information collected is not personally identifiable and cannot be used to identify you.

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

4.4 Personal information you provide directly 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, in accordance with the applicable legal basis.

For details on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following sets out the reasons and legal grounds on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party service providers, including hosting and storage providers, IP address data handlers, and user experience analytics firms.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transmit the Personal Data you have provided to us directly to those platforms. Your Personal Data may be shared with more than one trading platform, and its use will be governed by their respective privacy policies.

6.3 The Company may share Personal Data with related entities or business partners to support the enhancement and improvement of the products and services provided to its customers.

Where necessary to protect the rights of third parties or their assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

We may also 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 assets — or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party service providers, such as advertisers and analytics companies, that operate on our website. These third parties may also use cookies or similar tracking technologies.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.

Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. These are used to recognise you as a returning user and help you resume access to the Website.

Please note that disabling certain features may cause parts of the Website to behave unexpectedly or not function as intended.

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

8. Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for any longer period permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will do so for a further 12 months.

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organizations. The Company takes all necessary steps to protect the personal data you provide, ensuring that data subjects can assert their rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@clearvaulmere.com

10. Security of Personal Data

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

We cannot guarantee that your Personal Data will be kept secure at all times or free from error. We are not liable for any incidental or consequential damages arising from the use or disclosure of Personal Data, including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

10.3 In certain circumstances, we may be legally or otherwise required to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties protect your Personal Data.

10.4 Transmitting Personal Data over the internet cannot be guaranteed to be fully secure. The Company cannot ensure the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

Our website contains links to third-party websites and applications. These are not operated or supervised by the Company, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such third-party sites or applications.

11.2 When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. You should also consider carefully what Personal Data you share with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.

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

Unless otherwise specified, amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You may request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. 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 information on the rights available to you regarding your Personal Data. To exercise any of these rights, send a written request to the email address below.

13.3 Access rights You have the right to verify that the Company is processing your Personal Data accurately and, where it is, to access that data. The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for any additional copies. This data will be provided electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse to fulfill it or limit the scope of its response.

13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request the correction of incomplete Personal Data relating to you, taking into account the purpose for which it is processed.

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 purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to the processing of your Personal Data based on a reason specific to your situation, where processing is based on legitimate interests pursued by Us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to fulfil a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where such a restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the right to receive your Personal Data in a structured, commonly used format. You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.

13.9 Right to Refuse Consent You may withdraw your consent for Us to process your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. Please note that the laws of the European Union and its Member States may limit the rights described in this section 13 as they apply to your Personal Data.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, along with the reasons, within one month of receiving your request.

Subject to section 13 of the law, information requested under your rights in that section will be provided at no cost. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide suitable verification of their identity.