Privacy Policy

1. The Scope

This policy outlines what Personal Data the Company collects from individuals and how it processes, shares, and protects that information.

This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified either directly or through a combination of additional information that we hold or can reasonably access.

The Policy defines "processing" as any activity involving the collection or use of Personal Data, including its management, organisation, and storage.

Our services are intended for general audiences and are not designed for anyone under 18 years old. We do not knowingly collect information from people younger than 18, nor do we knowingly permit them to use our services. If we become aware that a child has provided us with information, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our service, channels, or website, we collect your Personal Data. In some cases, we may also ask you to provide it.

In some cases, we collect your Personal Data by analysing how you use our Services and service channels, or by receiving information about you from our third-party partners.

3. No Requirement to Disclose Personal Information

You're not required to provide us with any personal data. However, in certain circumstances, failure to supply personal data may prevent us from delivering our services or allow users to access the website.

4. What Personal Data We Collect

4.2 The information you collect is not personal information and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when you connect with a third-party online trading platform through us.

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

5.3 Contact us by email for further information about the processing required to protect our legitimate interests.

5.4 Below are the reasons and legal grounds on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, including IP address information and user experience analytics.

6.2 You can also ask us to share your Personal Data with third-party trading platforms. We will provide the Personal Data you give us to these third-party platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners to obtain the resources needed to enhance and improve the products and services it provides to its customers.

6.4 If disclosure is necessary to protect the rights of third parties or assets, the Company may share Personal Data with regulatory, local, or other official authorities.

6.5 We may also share your Personal Data with potential investors, buyers, or lenders to the Company or other group companies in connection with any transaction, including asset transfers or sales, mergers, restructuring, consolidations, or bankruptcies involving the Company or other group entities.

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 also use cookies and other tracking technologies.

7.2 Cookies are small text files stored on your device when you visit or access the website. We use cookies to collect information about your preferences and browsing habits, so we can improve your experience, remember your settings, and personalise the products and services we offer you. We also use cookies for statistics and analytics.

7.3 We use two main types of cookies: session cookies and persistent cookies. Session cookies are temporary and are deleted when you close your browser. Persistent cookies remain on your device after you close your browser and help us recognise you as a returning user, allowing you to return to the website more easily.

7.5 However, be aware that certain functions or the entire Website's features may not work as expected in this scenario.

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

8. Retention of Personal Data

The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for such longer periods as permitted by applicable law, regulations, policies, and relevant orders.

We'll share your information with third-party trading platforms for 12 months. If you consent, we'll continue sharing your data for a further 12 months.

We regularly review the Personal Data we hold to ensure it's still necessary.

9. International Transfers

Your personal information may be transferred to other countries (for example, your personal data may be sent to a third country or international organisations). The Company takes all necessary steps to protect your Personal Data and ensure that data users can assert their 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. To request this information, email: support@warvyn-ecomere.com

10. Security of Personal Data

We've implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your Personal Data will remain secure at all times. We are not liable for any indirect, incidental, or consequential damages that result from the use or disclosure of your Personal Data. This includes, but is not limited to, disclosure due to transmission errors, unauthorised third-party access, or other circumstances beyond our control.

10.3 If we're required by law or other circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we must comply. We cannot guarantee the security measures these third parties apply to your data in such situations.

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

11. Hyperlinks to Third Party Websites

We provide links to third-party websites and applications on our site. These external platforms are not operated by us, and we're not responsible for how they collect or process your personal data. Our privacy policy doesn't apply to your activity on those third-party sites or apps.

When you visit any third-party websites or apps, we recommend reading their privacy policies before accessing or using them. We also suggest reviewing what Personal Data you share with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If we make changes, we'll notify you by posting the updated Policy on our website.

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

12.3 Any amendments, unless explicitly stated otherwise, will take effect following publication of the revised Policy.

13. Your Rights

You're entitled to request that we verify the accuracy of Personal Data collected about you, correct any errors, and delete Personal Data we no longer need. You may also restrict how we process your personal information.

If you're an EEA resident, please refer to this page for information about your rights regarding your Personal Data. You can exercise these rights by emailing the address below.

13.3 Access rights The Company can verify the accuracy of your Personal Data and the processing activities involved. If verification confirms processing, you have the right to access your Personal Data. The Company will provide an electronic copy of your Personal Data at no charge, though a reasonable fee may apply for additional copies. Data will be supplied electronically upon request. Your right to access Personal Data must not conflict with the rights and freedoms of others. If a request would harm another person's rights or freedoms, the Company may refuse the request or limit what it can provide.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data about you be corrected, depending on the purpose of processing.

13.5 Right to Erasure You may request erasure of your Personal Data for the following reasons: (a) the data are no longer needed for the purpose for which they were collected or processed; (b) you withdraw consent and no legal basis remains for processing; (c) you object at any time, for reasons specific to your situation, to processing of your Personal Data based on legitimate interests pursued by us or a third party; (d) the Personal Data are processed unlawfully; or (e) the data must be removed to comply with a legal obligation. This right does not apply where processing is necessary (a) to fulfil an obligation required under EU or Member State law, or (b) to establish, exercise or defend legal claims.

13.6 Processing restrictions If you're concerned about the accuracy of your Personal Data, you can request that the Company limit how it's processed. Once Personal Data is restricted, it may only be retained if you consent to this, or if it's necessary to establish, exercise, or defend legal rights—either your own or those of another individual—or where there's a significant public interest reason recognised by the European Union or a Member State.

13.7 Right to data portability If processing is carried out by an automated system and is based on your consent or a contract you are party to, you have the legal right to review your Personal Data provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your right to erasure is not affected by exercising your right to data portability. The right to data portability does not affect the rights or freedoms of any other person.

13.8 Right to challenge You can object at any time to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This includes objections to profiling based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may only continue processing if you can show that your rights, freedoms, or interests outweigh our grounds, or if processing is necessary to establish, exercise, or defend legal rights. For direct marketing, you have the right to object to processing of your Personal Data 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 won't affect the legality of any processing that relied on your consent before you withdrew it. You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by an EU member state to protect the fundamental rights of individuals regarding Personal Data processing within the European Union. EU and member state laws may limit your rights concerning your Personal Data, as set out in this section 13.

13.10 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. The timeframe may be extended to up to two months if necessary, depending on the nature and complexity of the request. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.

13.11 Subject to the provisions of section 13 of the law, we will provide the information you request under your section 13 rights at no cost. If your request is unjustified or excessive — particularly if repeated — we may charge a reasonable fee to cover our administrative costs for providing the information or taking the action you've requested. We may also decline to act.

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