Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, and how that data is processed, shared with third parties, and secured.

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.

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

Our services are intended for general audiences. We do not permit anyone under the age of 18 to use them, and we do not knowingly collect information from minors. If we become aware that we hold personal data belonging to a person under 18, 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is not personal data and cannot be used to identify you.

4.3 Personal data we receive from you: any personal data you choose to provide to us when connecting with 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 more information about the processing we carry out to protect legitimate interests, please contact us by email.

5.4 The following sets out the purposes and legal bases 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, as well as companies that process IP address information and analyse user experience data.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data to those platforms as requested. Your Personal Data shared in this way will be governed by their respective privacy policies. Please note that your Personal Data may be disclosed to more than one third-party trading platform.

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 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 other group company in connection with a transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party service providers, such as advertising networks and analytics companies. These third parties may use cookies or similar technologies on our website.

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

Some cookies used on this Website 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 the browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you pick up where you left off.

Please note that disabling certain settings may prevent some or all Website features from working as intended.

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

8. Retention of Personal Data

The Company will 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, or orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. With your continued consent, we will extend this sharing 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 your personal data and ensure that you retain the ability to assert your 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@cleargrowstead.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 without error, nor can we accept liability for any intangible, 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, unauthorised third-party access, or other causes beyond our control.

In certain circumstances, we may be legally or otherwise required to share your Personal Data with third parties, such as public authorities. In these situations, we have no control over how those third parties handle or protect your Personal Data.

10.4 Transmitting Personal Data over the internet carries inherent security risks. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

Our website may contain 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, read their privacy policies before deciding to access or use them. Exercise caution when sharing any Personal Data with third parties.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, the updated Policy will be posted 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, any amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You have the right to request verification of the accuracy of your Personal Data, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the scope of processing of your personal data.

If you are a resident of the EEA, please refer to this page. You have the right to access and manage your Personal Data as described. To exercise any of these rights, please 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 Personal Data is being processed, you have the right to access it. The Company will provide an electronic copy of your Personal Data and may charge a reasonable fee for additional copies. Where requested, data will be made available in electronic format. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.

13.4 Right to rectification The Company may rectify inaccurate Personal Data at any time. You have the right to request that incomplete Personal Data relating to you be corrected, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request the 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, on grounds relating to your specific situation, to processing of your Personal Data that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) erasure is required to comply with 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 ground 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 does 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 such grounds exist, we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or unless processing is necessary for the establishment, exercise, or defence of legal rights. 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 our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal. You are entitled to lodge a complaint with your relevant 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 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 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity and volume of requests. We will notify you of any extension, and the reason for it, within one month of receiving your request.

Subject to section 13 of the law, information provided in response to a request made under your section 13 rights will be supplied free of charge. Where a request is unjustified or excessive, particularly where requests are repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act on the request.

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