Privacy Policy
We (also referred to as "We", "Us" or "Our") are committed to safeguarding your Personal Data and your privacy.
This Privacy Policy is designed to inform you about how we collect and store the information you provide through the website https://zephyrvermode.com (the Zephyr Vermode).
These principles will be upheld:
We want you to be able to make informed choices regarding the use and processing of Personal Data. We use different methods and procedures to provide you with relevant information. If we believe you require specific details, we’ll provide that information to you at the appropriate date and time. We are happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope?
This policy describes the types of Personal Data Zephyr Vermode collects about natural individuals and how it processes it, shares it with third parties, secures those processes, and related matters.
This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person can be defined as someone who can be identified directly or through a combination of additional information we hold or can access.
The Policy defines "processing" as a process that requires the use or collection of Personal Data. It includes the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old. We do not knowingly allow such persons to use our services. If we learn that we hold any information about children, we will delete it as quickly as we can.
2. What personal data do we hold about you?
If you access the service and channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain instances. In other instances, we collect your Personal Data by analysing your use of our Services or our service channels, or by receiving your information from our third-party partners.
3. You are not required to disclose personal information to the company, with no consequences.
However, you are not obliged to provide Us with any Personal Data. In certain circumstances, however, if you choose not to supply Us with Personal Data, this could hinder Us from offering the Services or hinder users from accessing the website.
4. What kinds of Personal Data can We collect? When you visit our website, we collect the following personal information:
This includes information about your online activity log, data about your traffic (including your IP address, the date of access, the time of access and the date of access), the language you used, software crash logs, the type of browser used, as well as information about the device you used. The information we collect is not private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us by choice when you connect with a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your complete name, address, phone number, and email address.
5. The legal basis and reasons for the processing of personal data
Your Personal Data is processed by the Company for the purposes described in this section, and in accordance with the legal basis that applies to it.
Without a legal basis, the Company is not able to use Personal Data concerning you. The legal grounds on which the Company is able to process Personal Data regarding you are:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies where you submit personal information via the Website so we can transfer it to a third-party trading platform.
- The Company or a third-party may need to process data to meet their legitimate interest. For instance, this may be necessary to improve Our Services or to defend legal claims.
- Processing must comply with a legal obligation.
Contact us by email for more details about the processing required to protect the legitimate interests.
Below is a list of the reasons and legal grounds we may rely on to use the information you provide us with. Personal Data.
Scope, Legal Basis
1. To provide your personal information to third parties at your request so you can access digital trading. If you ask us, we may request Personal Data from you to forward it to third-party companies.
You have given your consent to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns. Personal Data is necessary to help us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. To meet any legal obligation or administrative, judicial or legal requirement, Personal Data is processed to comply with legal requirements.
To comply with legal obligations, processing is required.
4. To enhance Our Services. We may use Personal Data to improve Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To perform and manage actions that align with the requirements of Our Services. These activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
7. To conduct analysis, including statistical analysis. To make decisions on different issues, we use various analytical techniques (including statistical methods).
Processing is necessary for the legitimate interests of the Company or a third party.
8.
To safeguard our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
Personal Data may be processed by us to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. Transfer of Personal Data to a Third Party
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analysis.
You can also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you provide to Us to those third-party trading platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This can provide the Company with the resources needed to enhance and improve the products and services it provides to its customers.
Where necessary to safeguard the rights or assets of third parties, The Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in the group of companies, if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group ) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.
7. Cookies and services from third parties
Third-party services, such as advertising providers on our website or analytics companies, may be used. These companies may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve the user experience, remember your preferences and tailor products and services you may find useful. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short time until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after you close your browser. They are used to help the Website identify you as a returning user and allow you to return to the website.
Types of Cookies:
We may use them according to their purpose:
1. Cookies are strictly necessary
These cookies are necessary for you to access the features you've requested and to navigate our website. Cookies are used to provide the information, products and services you have asked us for.
They are required for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you've previously visited.
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are erased once you close your web browser (session Cookies).
2. Functionality Cookies
Cookies help us recognise you each time you visit our site and save your settings and preferences.
Cookies collect Personal Data, such as your username, and the date of your last login to confirm that you are logged in to the site. They are deleted when you close your web browser (session Cookies).
3. Cookies for performance
Cookies are used to gather statistical data on the site's performance and help improve it. They also allow us to carry out analysis on our website.
Cookies store anonymous data that is not associated with any identifiable or identified natural person. They can be deleted when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or have been removed
To prevent or remove cookies, you need to adjust your browser's settings. Below are links to help you with the process for a few of the most well-known browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that some or all of the Website's functions and features might not work as you expect if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of personal data about You
The Company will retain Personal Data about you for as long as necessary to fulfil the purpose of processing Personal Data, as described in this Policy, or for longer periods as permitted by law or regulations, policies, and applicable orders.
We will share your information with third-party trading platforms for a period of 12 months. If you agree to this, we will continue to share your data for another 12 months.
We regularly review the Personal Data we hold to ensure it is not retained longer than needed.
9. Transfers of personal information to a third country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country (i.e. a country other than the one in which you reside) or to international organisations or jurisdictions). The Company takes all necessary steps to protect the Personal Data you provide and ensure that data users can assert their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate security for Personal Data transferred to it in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information about the security measures it uses to protect your Personal Data when it is transferred to third-party countries or international organisations. Please send an email to info@zephyrvermode.com
10. Security of Personal Data
We have taken appropriate organisational and technical precautions to safeguard Personal Data. This includes preventing accidental or unlawful destruction, loss or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data being disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.
If legal or other obligations beyond our control arise, we may be required to provide Personal Data concerning you to third parties, such as public authorities. We cannot control the security provided to your Personal Data by third parties in these situations.
Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to websites owned by third parties
Links to third-party sites and applications are provided on the website. These applications and websites are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any of the third-party websites or apps, we recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest doing this before providing any Personal Data to them.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest doing this before providing any Personal Data to them.
13. Your rights in relation to your personal information
You are entitled to ask Us to verify the accuracy of Personal Data being collected about you, to correct any mistakes, and to delete any Personal Data not required by Us. You may also restrict the types of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you in relation to the information you provide and your Personal Data. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company can verify whether Personal Data about you is being processed accurately. If it is, you may access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you ask for it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request adversely affects the rights and freedoms of another person, the Company may refuse to comply with the request or limit how it fulfils it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of processing.
Right to Erasure
The following reasons apply: (a) Personal Data is no longer required for the purpose for which it was collected or processed; (b) You withdraw consent and there is no legal basis to process it; (c) You object at any time, due to a reason specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued either by Us or by a third party; (e) Personal Data is unlawfully processed; or (f) Personal Data must be removed to meet the company's legal obligation.
This right does not apply if the processing is necessary (a) to fulfil an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to create, exercise or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data.
If you ask that Personal Data be restricted, Personal Data may only be kept if you give consent, or to create, exercise or defend legal rights, to defend the rights of another natural person, or where there is a reason of significant public interest within the European Union or a Member State.
Right to data portability
If the processing is carried out by an automated system and is based on consent or a contract that you are part of, you have the legal right to receive and review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, if technically feasible. Your rights under the right of erasure do not change because you exercise your right to data portability. The right to transfer data does not interfere with the rights or liberties of anyone else.
Right to challenge
You have the right to object at any time to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on these legitimate interests. If we can establish compelling legitimate grounds for processing Personal Data, we may continue to do so unless you can show that your rights, freedoms, or interests, or the exercise, establishment or defence of legal rights, outweigh those grounds.
Concerning direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to refuse consent
You may revoke your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing that depended on your consent before it was withdrawn.
You are entitled to lodge a complaint with the authority that supervises you.
You may lodge an appeal with a supervisory authority set up by a Member State to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
We will provide you with the requested information in accordance with your rights under section 13 of this agreement within a month after receiving your request. The time frame may be extended by up to two months if needed, depending on the nature of the request and the number of requests. Within one month after receiving your request, we will notify you of any extension and the reasons for it.
As long as it is not contrary to the provisions of section 13 of the law, the information you request under your rights in section 13 will be made available free of cost. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative expenses for providing the information or taking the action requested. We may also decline to act.
If we have doubts about the identity of the person who submitted your request, the Company may ask for further information.