Privacy Policy

We are committed to being transparent about how we collect and process your personal information.

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods to keep you informed and provide relevant information about Personal Data handling.
Where specific details are required, we will communicate them to you at the appropriate time.
If you have any questions or need clarification on any legally imposed limitations, we are happy to help. You can reach us by email at the address below: info@clearworthimandry.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for several purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site; to protect our rights and interests; to maintain and deliver the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities that support the use of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights over your Personal Data, you have access to a range of dedicated tools.

To exercise your rights, contact us at any time to submit a request regarding your personal data. We can update or delete your data, restrict its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request accordingly.

Protect Your Personal Data:

While we cannot guarantee absolute security of your personal data, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the personal data we collect about individuals, how we process it, share it with third parties, and keep it secure. This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of additional information we hold or can reasonably access. "Processing" refers to any activity involving the use or collection of personal data, including its organisation, structuring, and storage. Our services are intended for users aged 18 and above. We do not knowingly collect information from, or permit access to, anyone under the age of 18. If we become aware that personal data belonging to a minor has been collected, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. Depending on the situation, we may request it directly from you, gather it through analysis of how you use our services or channels, or receive it from our third-party partners.

You are not required to disclose personal information to the company. However, withholding such information may prevent us from delivering our Services or granting you access to the website.

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

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information such as your online activity log, traffic data (including IP address, access dates, and access times), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data we receive from you: any personal data you voluntarily provide when connecting with a third-party online trading platform through us.
Personal information provided to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: Where required by law — We may disclose your personal data to regulatory or government authorities when legally obligated to do so. Service providers — We share personal data with trusted third-party service providers who assist us in operating our platform and delivering our services. These parties are contractually bound to handle your data securely and only for the purposes we specify. Business transfers — In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party. We will notify you before your personal data becomes subject to a different privacy policy. With your consent — We may share your personal data with other third parties where you have given explicit consent. All third parties with whom we share personal data are required to maintain appropriate security measures and to use your data only for the purposes for which it was disclosed. We do not sell your personal data to third parties.

We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers, as well as companies that analyse user experience data such as IP address information.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be disclosed to those platforms and will be subject to their respective privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with affiliated entities or business partners where doing so enables us to enhance and improve the products and services we offer our customers.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within our group — in connection with a proposed or completed transaction, including any transfer or sale of assets, merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other entity within the group.

7. Cookies and Third-Party Services Our website uses cookies and services provided by third parties. These third parties may collect and process your personal data in accordance with their own privacy policies. By using our website, you acknowledge that third-party cookies may be placed on your device and that such third parties may access certain information about your browsing activity on our platform. We use third-party services for purposes including analytics, advertising, and functionality improvements. These services operate independently, and we do not control how third parties collect, store, or use your data. We encourage you to review the privacy policies of any third-party services you interact with through our website. You may manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website and limit your access to some features.

We may work with third-party service providers, including advertisers and analytics companies, that operate on our website. These providers may also use cookies or similar tracking technologies.
Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytics purposes.
We use two types of cookies. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and allow the website to recognise you as a returning user, making it easier to pick up where you left off.

Types of Cookies:

We may use them based on their purpose.

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.
We share your information with third-party trading platforms for a period of 12 months. If you consent to continued sharing, we will do so for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

Transfers of Personal Information to a Third-Party Country or International Organisation When we transfer your personal data to a third-party country or international organisation, we do so in accordance with applicable data protection requirements. Such transfers occur only where necessary to deliver our services or fulfil our legal obligations. We take appropriate safeguards to ensure your personal data remains protected during any cross-border transfer, regardless of the destination country's local data protection standards. Where required, we will rely on recognised legal mechanisms — such as adequacy decisions, standard contractual clauses, or other approved transfer tools — to legitimise the transfer and protect your rights. If you have questions about how your personal data is handled during international transfers, you may contact us using the details provided in this policy.

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organisational measures to safeguard it against unauthorised access, loss, misuse, alteration, or destruction. While we maintain appropriate security controls, no method of data transmission or storage is completely secure. We cannot guarantee absolute security, and you share personal data at your own risk. You are responsible for keeping your account credentials confidential. Do not share your password or account access with anyone. Notify us immediately if you suspect any unauthorised access to your account. We retain personal data only as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Once no longer needed, personal data is securely deleted or anonymised in accordance with our data retention procedures. Where we engage third parties to process personal data on our behalf, we require them to apply appropriate security standards and to handle your data solely for the purposes we specify. In the event of a personal data breach that poses a risk to your rights or interests, we will take prompt action in accordance with our legal obligations, which may include notifying the relevant supervisory authority and, where required, affected individuals. If you have concerns about the security of your personal data, contact us using the details provided in this policy.

We have implemented appropriate organizational and technical measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your personal data will be maintained without error, nor can we accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, personal data disclosed due to transmission errors, unauthorized third-party access, or other causes beyond our control. Where legal or regulatory obligations require it, we may be required to disclose personal data to third parties, including public authorities. In such circumstances, we have no control over the security measures applied by those third parties. Transmitting personal data over the internet cannot be guaranteed as fully secure. We cannot ensure the security of any personal data you transmit to us through the internet.

11. Links to Third-Party Websites

Our website includes links to third-party websites and applications. These sites and apps are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through them.
Before accessing or using any third-party website or app, we recommend reading their privacy policy carefully and exercising caution when sharing any Personal Data with them.

12. Modifications to this Policy We may update this Policy from time to time. When we do, the revised version will be posted on our website with an updated effective date. We encourage you to review this Policy periodically to stay informed of any changes. Your continued use of our services after any update constitutes your acceptance of the revised Policy.

Before visiting any third-party website or app, read their privacy policy carefully. Only provide your personal data to them once you are satisfied with how it will be handled.

13. Your Rights Over Your Personal Information You have certain rights regarding the personal information we hold about you. These rights may vary depending on your location and the nature of your data, but generally include the following: Right to access. You may request a copy of the personal information we hold about you, along with details of how we use it. Right to correction. If any personal information we hold is inaccurate or incomplete, you may ask us to correct or update it. Right to erasure. In certain circumstances, you may request that we delete your personal information. This right is not absolute and may be limited where we are required to retain data for legal or regulatory purposes. Right to restrict processing. You may ask us to limit how we use your personal information in certain situations — for example, while we verify a correction request. Right to data portability. Where applicable, you may request that we transfer your personal information to you or a third party in a structured, commonly used format. Right to object. You may object to the processing of your personal information where we rely on legitimate interests as our legal basis, including for direct marketing purposes. Right to withdraw consent. Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. To exercise any of these rights, contact us using the details provided in this policy. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing your request.

You have the right to 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 scope or type of processing applied to your Personal Data.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, send a written request to the email address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. Where confirmed, you may access that Personal Data.
The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. 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 another person's rights or freedoms, the Company may refuse or limit its response.
Right to rectification
The Company will correct inaccurate Personal Data. You may request that incomplete Personal Data concerning you be completed, taking into account the purpose of processing.
Right to erasure
This right applies where: (a) Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, on grounds specific to your situation, to processing of Personal Data about you that is based on legitimate interests pursued by us or a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal claims, or to protect the rights of another individual, or on grounds of significant public interest within the European Union or a Member State.
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 request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not affect the rights or freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data about you based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defense of legal claims, we will cease processing.
Regarding direct marketing, you have the right at any time to object to the processing of Personal Data about you for that purpose.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals' fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights in relation to your Personal Data, as set out in this section 13.
We will respond to requests made under the rights set out in section 13 within one month of receipt. Where necessary, given the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension and the reasons for it within one month of receiving your request.
Unless otherwise provided under section 13, information provided in response to your rights requests will be supplied free of charge. Where requests are unfounded or excessive, in particular where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to confirm identity.