Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about 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 directly identified, or identified 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 persons under 18, nor do we permit them to use our services. If we become aware that any such information has been collected, 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 also request personal data directly 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 our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide us with any Personal Data. However, withholding certain Personal Data may prevent us from delivering the Services or restrict your 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 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 details about the processing carried out to protect 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, as well as platforms used to analyse user experience and IP address information.

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 shared in this way is governed by the privacy policies of the respective third-party trading platforms. 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.

6.4 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, a merger, restructuring, consolidation, or bankruptcy of the Company or any other entity within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertisers and analytics providers, on our website. These third parties may also use cookies or similar technologies.

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 analytics 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 resume your session.

Please note that disabling certain site functions may cause parts of the Website to behave unexpectedly or not work as intended.

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 purposes described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, or orders.

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

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

Your personal information may be transferred to other countries or to international organisations. We take all necessary steps to protect your personal data and ensure you retain the ability to assert your rights and access effective legal recourse.

9.3 We can provide details on 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 us at: support@zephgain.com

10. Security of Personal Data

We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or modification.

We cannot guarantee that your Personal Data will be kept secure at all times and free from error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

In certain circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, including 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 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 Our website may contain links to third-party sites and applications. These sites and applications are not operated or supervised by the Company. 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.

When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. We also suggest carefully considering what personal data you share with them.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be communicated by posting the revised Policy 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 we hold, to have any inaccuracies corrected, and to request deletion of personal data we no longer require. You may also restrict the types or scope 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 additional copies. 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 or limit its response accordingly.

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, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request 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 specific to your situation, to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data are 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 ask the Company to restrict its processing. Where a restriction is in place, 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 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 and to request that it be transferred directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.

13.8 Right to object You have the right at any time to object 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 the 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 process your Personal Data. 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 to 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 have the right to lodge a complaint with your 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 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 provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. If the complexity or volume of requests requires it, this period may be extended by up to two additional months. 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 requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover the administrative costs of providing the information or fulfilling 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.