Privacy Policy
At Clear Ledgeroment, we are committed to protecting your personal data and your privacy.
This Privacy Policy explains how we collect and store information you provide through https://clearledgeroment.com.
The following principles apply:
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods to keep you appropriately informed, and will provide specific details when relevant and timely. We are available to answer any questions regarding applicable legal limitations.
1. The Scope?
This policy describes the types of personal data Clear Ledgeroment collects about individuals, 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 recognized directly or through a combination of information we hold or can reasonably access.
"Processing" refers to any operation involving personal data, including its collection, organization, storage, and management.
Our services are intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data has been collected from a minor, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you access our services, channels, or website, we collect Personal Data. Depending on the context, we may request it directly from you, gather it by analyzing how our services and channels are used, or receive it from third-party partners.
3. You are not required to provide personal information to the company. However, withholding it may prevent us from delivering our services or granting you access to the website.
Providing personal data is not mandatory. However, choosing not to share certain personal data may prevent us from delivering our Services or granting you access to the website.
4. What personal data do we collect? When you visit our website, we collect the following personal data from you:
This includes information such as your online activity log, traffic data (including your IP address, access dates, and access times), language settings, software crash reports, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data we receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal information provided 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 Personal Data
Your personal data is processed by the Company for the purposes described in this section, in accordance with the applicable legal basis.
The Company may only process personal data concerning you when a valid legal basis exists. The legal grounds upon which the Company may process your personal data are:
- By submitting personal data through this Website, you consent to its processing for one or more specified purposes, including its transfer to a third-party trading platform.
- In some cases, we or a third party may need to process your data to pursue legitimate interests — such as improving our Services or defending legal claims.
- Processing is required to fulfil a legal obligation.
For more information about the processing used to protect our legitimate interests, please contact us by email.
The following outlines the reasons and legal grounds on which we may use the personal data you provide.
Scope, Legal Basis
1. At your request, we may share your personal data with third-party companies to facilitate access to digital trading.
You have consented to the processing of your personal data for one or more purposes.
2. We use your personal data to respond to your questions, requests, and concerns about our Services.
Processing is required to serve the legitimate interests of the Company or a third party.
3. Personal data is processed to meet applicable legal, administrative, and judicial obligations.
Processing is required to meet legal obligations.
4. We may use personal data to improve our Services, including through crash reports and malfunction data collected in connection with the Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our Services
Processing is required to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services — including back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is required to serve the legitimate interests of the Company or a third party.
7. We use analytical techniques, including statistical methods, to support decision-making across a range of issues.
Processing is required to support the legitimate interests of the Company or a third party.
8. To protect our assets, rights, and interests — as well as those of third parties — we may process Personal Data to establish or defend legal claims, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing of your personal data may be necessary to support the legitimate interests of the Company or a third party.
6. Sharing Personal Data with Third Parties We may share your personal data with third parties in the following circumstances: Service Providers: We work with trusted third-party service providers who assist in operating our platform and delivering our services. These providers are granted access to your personal data only to the extent necessary to perform their functions and are contractually required to protect it. Legal and Regulatory Obligations: We may disclose your personal data when required by law, regulation, or court order, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others. Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such change and any choices you may have regarding your personal data. Consent-Based Sharing: Where you have provided explicit consent, we may share your personal data with third parties for the purposes you have authorized. We do not sell your personal data to third parties. All third-party data sharing is conducted in accordance with applicable privacy requirements and is limited to what is necessary for the stated purpose.
We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers and user experience analytics services. Upon your request, we may transfer specific Personal Data to third-party trading platforms. In such cases, your Personal Data will be shared with those platforms and will be subject to their respective privacy policies. Your Personal Data may be shared with more than one trading platform. We may also share Personal Data with affiliated entities or business partners where doing so enables us to maintain, enhance, or improve the products and services we offer our customers. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, government, or other competent authorities. We may share your Personal Data with prospective investors, acquirers, or lenders — whether in relation to the Company or any entity within our group — in connection with any proposed or completed transaction, including the sale or transfer of assets, or any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any group entity.
7. Third-Party Cookies and Services
We may work with third-party services, such as advertising providers and analytics companies, that operate on our website. These third parties may also use cookies or similar technologies. 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 content to your interests. Cookies are also used for statistical and analytics purposes. We use two types of cookies. Session cookies are temporary and are removed from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and help the website recognize you as a returning user, allowing for a more seamless experience on future visits.
Types of Cookies:
We may use them based on their purpose:
1. Essential cookies only
These cookies are required to give you access to the features you've requested and to help you navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and allow you to move between pages — including ones you've visited before.
Cookies collect personal data — such as your username and last login date — to verify that you're logged in. They are automatically deleted when you close your browser (session cookies).
2. Functionality Cookies
Cookies recognize you each time you visit our site and save your preferences.
Cookies collect personal data — such as your username and last login date — to verify that you are logged in. They are deleted when you close your browser (session cookies).
3. Cookies for performance
We use cookies to collect site performance data and support ongoing improvements to our website.
Cookies store anonymous data that is not linked to any identifiable individual. Session cookies are removed when you close your browser; others remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, adjust your browser's settings. Links to instructions for some of the most widely used browsers are provided below.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some or all of the Website's features and functions may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. How We Retain Your Personal Data
We 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, regulation, or order.
We share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We regularly review the personal data we hold to confirm it is no longer required.
9. International Transfers of Personal Information Where personal information is transferred to a third-party country or international organisation, such transfers are conducted in accordance with applicable data protection requirements to ensure your information remains protected.
Your personal information may be transferred to other countries or to international organizations outside the country in which you reside. 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.
These protections apply to all individuals residing in the European Economic Area (EEA).
- Transfers to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data, in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- This transfer is made under a legally binding and enforceable agreement between public entities or authorities, as provided under Article 46(2)(a).
- This transfer was conducted in accordance with standard contractual clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
To learn about the security measures used to protect your personal data when transferred to third-party countries or international organisations, contact us at info@clearledgeroment.com
10. Protecting Your Personal Data We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, loss, alteration, or disclosure. No method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee absolute security. Access to your personal data is restricted to employees, contractors, and agents who need it to perform their job functions. All individuals with access are bound by confidentiality obligations and may be subject to disciplinary action if they fail to meet these requirements. If you have reason to believe your personal data has been compromised, please contact us promptly so we can take appropriate action.
We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or modification. We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, any disclosure resulting from transmission errors, unauthorized third-party access, or other causes beyond our control. Where required by legal or other obligations beyond our control, we may be required to disclose Personal Data to third parties, such as public authorities. We cannot control how third parties protect your Personal Data in such circumstances. Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us online.
11. Links to Third-Party Websites
Our website may contain links to third-party websites and applications. These sites and apps are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through such sites or apps.
Before accessing or using any third-party website or application, we recommend reviewing its privacy policy. We also advise exercising caution before providing any Personal Data to third parties.
12. Policy Changes We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, we will notify you directly. Continued use of our services after any changes take effect constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed.
Before accessing or using any third-party websites or apps, review their privacy policies carefully. Use discretion when sharing any personal data with them.
13. Your rights regarding your personal information
You have the right to request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also restrict the types or scope of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
We can verify whether your Personal Data is being processed. If it is, you may access that Personal Data.
We will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If fulfilling a request would be detrimental to another person's rights or freedoms, we may refuse or limit our response.
Right to rectification
You have the right to have inaccurate Personal Data corrected. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is processed.
Right to erasure
This right applies where: (a) Personal Data is no longer necessary for the purpose for which it was 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) Personal Data is processed unlawfully; or (f) Personal Data must be deleted to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be stored unless you provide consent, or where necessary to establish, exercise, or defend legal rights, to protect the rights of another individual, or for reasons of substantial public interest within the European Union or a Member State.
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 format.
You may request that your Personal Data be transferred directly from us to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
Right to object
You have the right, at any time, to object to the processing of your Personal Data based on legitimate interests pursued by us or a third party, including profiling based on those interests. If we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defense of legal rights, we will cease processing.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
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 prior to that withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect the fundamental rights of individuals in connection with the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights in relation to your Personal Data as described in this section 13.
We will respond to requests made under your rights in section 13 within one month of receipt. Where necessary, given the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Unless otherwise provided under section 13, information provided in response to a request under your rights in section 13 will be provided free of charge. Where requests are unfounded or excessive, particularly where they are repetitive, we may charge a reasonable fee to cover administrative costs or decline to act.
Where we have reasonable doubts about the identity of the person making a request, we may ask for additional information to verify identity.