Privacy Policy

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects from natural individuals, and how it processes, shares with third parties, and secures that data.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through additional information we hold or can access.

1.3 Under this Policy, "processing" means any operation that uses or collects Personal Data, including its management, structuring, and storage.

1.4 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 any person under 18, nor do we knowingly permit such persons to use our services. If we learn that we hold any information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access our services and channels or visit our website. In certain cases, we may request your Personal Data directly.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are under no obligation to provide Us with any Personal Data. If you choose to withhold it, however, this may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.2 The information we collect 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 when you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to enable trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.

5.3 Contact us by email for more details about the processing necessary to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

6.1 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 analysis of user experiences.

6.2 You may also ask us to share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you give us to those third-party trading platforms, where its use is governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with affiliated entities or business partners. This gives the Company the resources to enhance and improve the products and services it provides to its customers.

6.4 To protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 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 such a transaction (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

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

7.2 Cookies are small text files placed on your device each time 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 that may suit you. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only until you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the Website recognise you as a returning user and make it easier to return to the site.

7.5 Be aware, however, that some or all of the Website's functions and features may not work as you expect if this occurs.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your personal data with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to a third country or to international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 To learn about the security measures we use to protect your Personal Data transferred to third-party countries or international organisations, email us at: support@pulavik-savanton.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational and technical measures to safeguard Personal Data, including protection against the accidental or unlawful destruction, loss, or modification of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error, and we are not liable 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 disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Where legal or other obligations beyond our control apply, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's control. 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 applications.

11.2 Before accessing or using any third-party website or app, we recommend reviewing its privacy policy and considering carefully what Personal Data you provide to them.

12. Modifications to This Policy

12.1 We may update this Policy at any time. When we make changes, we will notify you by posting the updated Policy on our website.

12.2 We will also notify you of significant changes to this Policy through methods we consider appropriate and will publish an announcement on our website.

12.3 Unless otherwise stated, any amendments take effect once the revised Policy is published.

13. Your Rights

13.1 You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the scope and types of processing applied to your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, 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. If you request it, the data will be supplied electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse the request or limit the extent to which it complies.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You have the right to request the rectification of incomplete Personal Data concerning you, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis for processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to comply with the company's legal obligation. This right does not apply where processing is necessary (a) to fulfil a legal obligation required to be processed under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Restriction of processing If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request such a restriction, your Personal Data may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of 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 on a contract to which you are a party, you have the legal right to receive the Personal Data you have provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data portability does not affect the rights or freedoms of others.

13.8 Right to object You may 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 on those legitimate interests. Where we can establish compelling legitimate grounds for processing, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests override those grounds, or that the processing is necessary for the exercise, establishment, or defense of legal rights. Where Personal Data is processed for direct marketing, you have the right to object at any time.

13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with the supervisory authority that oversees you. You may submit a complaint 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. The laws of the European Union and Member States may restrict your rights in relation to Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.

13.11 Unless section 13 of the law provides otherwise, the information you request under your section 13 rights will be provided free of charge. Where a request is unfounded or excessive, particularly if it is 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.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable means of identification.