Privacy Policy

1. The Scope

This policy outlines the types of personal data the Company collects from 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 indirectly through a combination of information we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" means 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 designed for 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 such information has been collected, we will delete it as promptly as possible.

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 instances, we may request specific Personal Data 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 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 you choose to provide when connecting to 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 information about the processing we carry out to protect legitimate interests, please contact us by email.

5.4 The following sets out 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, IP address data handlers, and user experience analytics platforms.

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 these instances will be subject to the privacy policies of the respective third-party trading platforms. Please note 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 enhance and improve 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 such as a transfer or sale of assets, merger, restructuring, consolidation, or bankruptcy involving the Company or any other business 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 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 allow the website to recognise you as a returning user and make it easier for you to return to the site.

7.5 Please note that disabling cookies may cause some or all Website features to behave unexpectedly or stop working altogether.

Online Tracking Notice: This service does not currently respond to 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 such longer periods as permitted by applicable laws, regulations, policies, or orders.

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

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

9. International Transfers

9.1 Your personal data 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 right to assert your rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@zenithmere.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 alteration.

We cannot guarantee that your Personal Data will be kept secure at all times or free from error. We are 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 some circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, including public authorities. In those situations, we have no control over how those third parties 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 sites or applications.

When visiting any third-party websites or apps, read their privacy policy before accessing or using their services. You should also consider carefully what personal data you choose to 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 have the right to request verification of the accuracy of your Personal Data, correct any inaccuracies, and request deletion of any Personal Data we no longer require. You may also restrict the scope of processing of 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, submit your request by email to the address below.

13.3 Access rights The Company may 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. If you request it, the data will be provided in electronic form. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its compliance with that request.

13.4 Right to rectification We may correct inaccurate Personal Data held about you. You may also request that incomplete Personal Data be rectified, taking into account 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 no other legal basis for processing exists; (c) you object, on grounds specific to your situation, to the processing of your Personal Data where that processing 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 fulfil 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 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 there is a substantial public interest reason 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 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 must 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 are able to 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 refuse consent You may withdraw your consent for Us processing 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 are entitled 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 the rights available to you 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 months. We will notify you of any such extension, along with the reasons, within one month of receiving your request.

Subject to section 13 of the law, information provided in response to a request made under your section 13 rights will be supplied at no cost. 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 carrying out the action requested. We may also decline to act on such requests.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide sufficient means of verifying their identity.