Privacy Policy

1. The Scope

This policy explains what personal data the Company collects about individuals, and how that data is processed, shared with third parties, and kept 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 information we hold or can reasonably access.

1.3 In 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 and are not available to anyone under the age of 18. We do not knowingly collect information from individuals under 18, nor do we permit them to use our services. If we become aware that such information has been collected, we will delete it promptly.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect personal data. In certain circumstances, we may request specific personal data from you.

2.2 In other cases, we 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 information 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 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 set out in this section, in accordance with the applicable legal basis.

For more information about the processing carried out to safeguard legitimate interests, please contact us by email.

5.4 The following outlines the purposes and legal grounds 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, for purposes such as IP address processing and user experience analysis.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms accordingly. Your Personal Data will then be subject to the privacy policies of those third-party trading platforms. Please be aware that your Personal Data may be shared with more than one 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 or buyers, or with lenders to the Company or any other company within the group, in connection with a transaction involving the transfer or sale of Company assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other entity within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party service providers, such as advertisers and analytics companies, that operate on our website. These third parties may also use cookies or similar tracking technologies.

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

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognise you as a returning user and allow you to pick up where you left off.

Please note that disabling certain Website functions may cause some or all features to behave unexpectedly.

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

8. Retention of Personal Data

We will 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.

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

8.3 We periodically review the Personal Data we hold to determine whether it is still required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.

9.3 We can provide details about the security measures used to protect your Personal Data when it is transferred to third-party countries or international organisations. To request this information, email: support@polarzinsmere.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational 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. We are not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including — but not limited to — disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.

In some circumstances, we may be legally or otherwise obligated to disclose your personal data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect your personal data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for the collection or processing of personal data by those sites or applications. This Policy does not apply to actions taken through them.

Before accessing or using any third-party websites or apps, we recommend reading their privacy policies. You should also consider carefully what personal data you share with them.

12. Modifications to This Policy

This Policy may be updated at any time. If changes are made, we will notify you by posting the updated Policy on our website.

12.2 When significant changes are made 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 may request that we verify the accuracy of the personal data we hold about you, correct any inaccuracies, and delete any personal data we no longer require. You may also restrict the types of processing applied to your personal data.

If you reside in the EEA, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where this is confirmed, you have the right to access that 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. Where access is requested, data will be made available in electronic form. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request is 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 We may correct any inaccurate Personal Data we hold about you. You may also request that incomplete Personal Data be rectified, having regard to 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 particular situation, to processing of your Personal Data that is based on legitimate interests pursued by us or a third party; (e) the Personal Data have been unlawfully processed; or (f) erasure is required to comply with a legal obligation applicable to 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 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. 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 a matter of significant public interest within the European Union or a Member State applies.

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 the Personal Data you have provided to the Company 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 we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to do so. 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 withdraw consent You may withdraw your consent for us to process your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent prior to that withdrawal. You have the right to lodge a complaint with a relevant supervisory authority. Within the European Union, you may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data. Please note that EU and Member State laws may limit your rights in relation to your Personal Data, as set out in this section 13.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights will be provided 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 reasonable doubts about the identity of the person submitting a request, we may ask that person to provide suitable means of identification.