Privacy Policy
We (also known as "We", "Us" or "Our") are committed to safeguarding your Personal Data and protecting your privacy.
This Privacy Policy is designed to inform you of how we collect and store the information you provide through the website https://suretanive.com (the Suretanive ).
The following principles will be upheld:
We want you to be well-informed when making decisions about the use and processing of your Personal Data. We use various methods and procedures to ensure you receive relevant information. Where specific details are required, we will provide them to you in a timely manner. We are happy to address any questions you may have regarding any limitations imposed by law.
1. The Scope?
This policy describes the types of Personal Data that Suretanive collects from natural individuals, and how it processes, shares with third parties, and secures such data.
This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person refers to someone who can be directly identified, or identified through a combination of additional information we hold or are able to access.
The Policy defines "processing" as any operation involving the use or collection of Personal Data, including its organisation, structuring, and storage.
Our services are intended for general audiences and are not designed for use by individuals under the age of 18. We do not knowingly seek or collect information from anyone younger than 18, nor do we knowingly permit such individuals to use our services. Should we become aware that we have collected information from a minor, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels or visit our website, we collect Personal Data. In certain instances, we may request your Personal Data directly. In other cases, we gather your Personal Data by analysing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. There is no requirement to disclose personal information to the company, nor any consequences for doing so.
You are not obliged to provide Us with any personal data. However, in certain circumstances, choosing not to supply Us with the required Personal Data may limit Our ability to offer the Services or prevent users from accessing the website.
4. What Personal Data Do We Collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity log, data about your traffic (including your IP address, date of access, time of access, and date of access), the language used, software crash logs, browser type, and information regarding the device you utilised. This information is not personal in nature and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide to Us when you connect with an online trading platform of a third party through Us.
Personal information you provide specifically to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.
5. The 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.
Without a valid legal basis, the Company is unable to process personal data relating to you. The legal grounds upon which the Company may rely to process your personal data are as follows:
- You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website so that we may transfer it to a third-party trading platform.
- The Company or a third party may need to process your information to fulfil a legitimate interest — for example, to improve Our Services or to defend legal claims.
- Processing is required to comply with a legal obligation.
Contact us via email for more details on the processing required to safeguard legitimate interests.
Below is a list of the reasons and legal grounds under which we may use the information you provide us. Personal Data.
Scope, Legal Basis
1. Upon your request for access to digital trading, we may share your personal information with third-party companies. Should you require this, we will collect the necessary Personal Data from you and forward it accordingly.
You have given your consent to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions, or concerns. Personal Data is necessary to respond to any queries you may have regarding the Services.
Processing is necessary to serve the legitimate interests of the Company or those of a relevant third party.
3. Personal data is processed to fulfil legal, administrative, and judicial obligations in compliance with applicable legal requirements.
Processing is required to comply with legal obligations.
4. Personal data may be used by us to improve Our Services. This includes, among other things, crash reports and malfunction data collected in relation to the Services.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary to serve the legitimate interests of the Company or a relevant third party.
6. To carry out and manage activities that align with the requirements of Our Services. This includes back-office operations, business development, strategic decision-making, oversight mechanisms, and related functions.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
7. To conduct analysis, including statistical analysis, and to make informed decisions on various matters, we employ a range of analytical techniques — including statistical methods.
Processing is necessary to fulfil the legitimate interests of the Company or those of a relevant third party.
8.
To protect our assets, rights, and interests, as well as those of third parties, we may process Personal Data to establish and defend legal claims.
Such processing is carried out to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing is necessary to serve the legitimate interests of the Company or those of a relevant third party.
6. Transfer of Personal Data to Third Parties
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 analytics.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data you have submitted to us directly to those third-party trading platforms. The use of your Personal Data will be governed by their respective privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners where doing so enables the Company to enhance and improve the products and services offered to its customers.
Where necessary to protect 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 within the group, in connection with a relevant 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 involving the Company or any other business within the group.
7. Cookies and Third-Party Services
Third-party services, such as advertising providers or analytics companies, may be engaged on our website. These companies may also make use of cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to enhance the user experience, remember your settings, and personalise the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for a short period before expiring when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They help the website recognise you as a returning user and allow you to resume your experience on the website seamlessly.
Types of Cookies:
They may be used by us according to their purpose:
1. Essential Cookies
These cookies are essential for accessing the features you have requested and for navigating our website. They enable us to deliver the information, products, and services you have asked for.
They are also required for your device to download and stream data, allowing you to browse the site, make use of its features, and return to pages you have previously visited.
Cookies collect Personal Data, such as your username and last login date, to verify that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
2. Functionality Cookies
Cookies allow us to recognise you each time you visit our site, and to save your settings and preferences.
Cookies collect Personal Data, such as your username and last login date, to verify that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
3. Cookies for performance
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to carry out analysis on our website.
Cookies store anonymous data that is not linked to any identified or identifiable individual. Some cookies are removed when you close your browser, while others remain valid indefinitely.
Cookies are blocked or removed
To manage or remove cookies, you will need to adjust your browser's settings. Below are links to guide you through the process for some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that if this occurs, some or all of the Website's functions and features may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. The Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing, as described in this Policy, or for such longer periods as permitted by applicable laws, regulations, policies, and orders.
Your information will be shared with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
We conduct regular reviews of the Personal Data we hold to ensure it is not retained beyond what is necessary.
9. Transfers of Personal Information to Third-Party Countries or International Organisations
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — one other than your country of residence — or to international organisations and jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that users are able to exercise their rights and access effective legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU 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").
- The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities, in accordance with 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. These clauses 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 on the security measures it employs to protect your Personal Data when transferred to third-party countries or international organisations. Please send an email to info@suretanive.com
10. Security of Personal Data
We have implemented appropriate organisational and technical measures to safeguard Personal Data, including protection 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, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or any other cause beyond our control.
In circumstances involving legal or regulatory obligations beyond our control, we may be required to disclose Personal Data to third parties, such as public authorities. In such situations, we are unable to control the level of security applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data that you transmit to us via the internet.
11. Links to Third-Party Websites
Links to third-party sites and applications may be found on this website. These external sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by such websites or applications, and this Policy does not apply to any actions taken through them.
When visiting any third-party website or application, we recommend that you review their privacy policies before choosing to access or use their services. We also advise that you exercise discretion when sharing any Personal Data with them.
12. Changes to This Policy
When visiting any third-party websites or apps, we recommend reviewing their privacy policies before choosing to access or use their services. We also advise caution when providing any Personal Data to these parties.
13. Your Rights Regarding Your Personal Information
You have the right to request that we verify the accuracy of the Personal Data collected about you, rectify any inaccuracies, and delete any Personal Data that we no longer require. You may also restrict the scope and types of processing of your personal information.
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 any of these rights, please send a written request to the email address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. Where applicable, 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. Data will be made available electronically upon request.
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 decline to comply or limit its ability to fulfil the request.
Right to rectification
The Company is obliged to rectify inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of processing.
Right to Erasure
The following grounds apply: (a) 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, based on reasons specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by us or a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the Company.
This right does not apply where processing is necessary (a) to fulfil a legal obligation required under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns regarding the accuracy of your Personal Data, you may request that the Company restrict its processing of your Personal Data.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, or to protect the rights of another individual, or where there is a 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 and review 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 right to erasure, and shall not infringe upon the rights or freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those legitimate interests. Unless the Company 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 will cease such processing.
With regard to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will 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 the relevant supervisory authority.
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 limit your rights in relation to Personal Data concerning you, as outlined in this section 13.
We will provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months where necessary, depending on the complexity and volume of requests. We will notify you of any such extension, along with the reasons, within one month of receiving your request.
Unless otherwise contrary to the provisions of section 13, information provided pursuant to your rights under section 13 will be made available free of charge. Where requests are unwarranted or excessive, particularly where they are repetitive, we may charge a reasonable fee to cover administrative costs, or we may decline to act.
If we have reasonable doubts regarding the identity of the person submitting a request, the Company may ask for additional information to verify their identity.