Privacy Policy

1. The Scope

This policy outlines the Personal Data we collect from individuals, how we process and share it with third parties, and the security measures we use to protect it.

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 access.

# 1.3 What "Processing" Means The Policy defines "processing" as any activity involving the collection or use of Personal Data. This includes managing, structuring, and storing Personal Data.

1.4 Our services are intended for general audiences and are not designed for anyone under 18 years old. We do not knowingly collect information from or allow use of our services by anyone under 18. If we discover information about a minor, 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. We may also request Personal Data from you in certain circumstances.

We collect your Personal Data by analyzing your use of our Services and service channels, and by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide personal data to us. However, in some circumstances, certain personal data is necessary for us to deliver the Services or for you to access the website. Without it, we may be unable to do so.

4. What Personal Data We Collect

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

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

Personal information you share with third-party trading platforms 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.

Contact us via email for details about protecting our legitimate interests.

5.4 Below are the reasons and legal grounds under which 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 platform operations and improve user experience.

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. Their use of your information is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.

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

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

We may share your personal data with potential investors, buyers, or lenders to the Company or any group company in connection with a proposed transaction, including asset transfer, sale, merger, restructuring, consolidation, or bankruptcy.

7. Cookies and Services from Third Parties

We use third-party services—such as advertising providers and analytics companies—to enhance our website. These partners may use cookies and similar technologies to deliver this functionality.

Cookies are small text files stored on your device when you visit our website. We use them to understand your preferences and browsing behavior, enhance your experience, remember your settings, and tailor the products and services we offer. Cookies also support our analytics and performance measurement.

7.3 We use two types of cookies on this website. Session cookies are temporary and 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 improve your experience.

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 honor 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 as required by applicable law, regulations, and regulatory 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 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 shared with 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 The Company can provide details about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. Contact us at: support@claugentor.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 resulting from the use or disclosure of your Personal Data, including but not limited to disclosure caused by transmission errors, unauthorized third-party access, or circumstances beyond our control.

10.3 We may be required by law or other obligations beyond our control 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.

Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of personal data you send to us online.

11. Hyperlinks to Third Party Websites

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

When visiting third-party websites or apps, review their privacy policies before accessing or using them. We also recommend that you review what Personal Data you share 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 stated otherwise.

13. Your Rights

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete Personal Data we no longer require. You may also limit the types of processing we perform on your Personal Data.

If you are an EEA resident, please refer to this page for your data rights. You have specific rights regarding the Personal Data you provide. To exercise these rights, email the 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. Additional copies may be supplied for a reasonable fee. Data will be made available electronically upon request. The right to access Personal Data must not interfere with the rights and freedoms of others. If your request would be detrimental to another person's rights or freedoms, the Company may refuse the request or limit its scope.

13.4 **Right to Rectification** We may correct any inaccurate Personal Data about you. You have the right to request correction of incomplete Personal Data, based on the purpose for which it is being processed.

13.5 Right to Erasure You may request erasure of your Personal Data in the following circumstances: (a) the 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 processing based on legitimate interests pursued by us or a third party, for reasons specific to your situation; (d) the data are processed unlawfully; or (e) we are required by law to delete the data. This right does not apply when processing is necessary to (i) fulfill a legal obligation under European Union law or Member State law, or (ii) 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 restrict its processing. Once Personal Data is restricted, it may only be retained with your consent, or to establish, exercise, or defend legal rights—either your own or those of another individual—or where processing is required for reasons of 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 the processing is based on your consent or a contract with the Company, you have the legal right to request your Personal Data and to have it transferred directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure or the rights and freedoms of others.

13.8 Right to Challenge You have the right to object at any time to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party. This right extends to any processing, including profiling, based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue only if those grounds outweigh your rights, freedoms, and interests, or are necessary for the establishment, exercise, or defense of legal claims. You also have the right to object at any time to the processing of your Personal Data for direct marketing purposes.

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 legality of any processing that relied on your consent before revocation. You have the right to lodge a complaint with your supervisory authority. If you are in the European Union, you may appeal to a data protection authority established by an EU member state to protect your fundamental rights regarding personal data processing. EU and member state laws may limit your rights concerning your personal data, as described 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 timeframe to up to two months, depending on the nature and volume of your requests. We will notify you of any extension and explain the reasons within one month of receiving your request.

Pursuant to section 13 of the law, we provide the information you request free of charge. If your request is unjustified, excessive, or repetitive, we may charge a reasonable fee to cover administrative costs. We also reserve the right to decline the request.

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