Privacy Policy

We are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://palmcapitora.net (the Palm Capitora).
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 properly informed, and where specific details are needed, we'll provide them at the appropriate time. We're also happy to answer any questions you may have about applicable legal limitations.

1. The Scope?

This policy describes the types of personal data Palm Capitora collects about natural 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. An identifiable natural person is someone who can be identified directly, or through a combination of additional information we hold or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its management, organisation, and storage.
Our services are intended for general audiences and are not designed for individuals under the age of 18. We do not knowingly seek or collect information from anyone under 18, and we do not knowingly permit such individuals to use our services. Any data we discover relating to a minor will be deleted as promptly as possible upon becoming aware of it.

2. What Personal Data Do We Hold About You?

When you access our Services, service channels, or website, we collect personal data. This may happen directly — when you provide it to us — or indirectly, through analysis of how you use our Services or by receiving your information from our third-party partners.

3. You are not required to share personal information with us. However, choosing not to may limit our ability to provide our services or grant you access to the website.

You are not required to provide us with any personal data. However, withholding it 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:

This includes information about your online activity log, traffic data (such as IP address, access dates and times, and browser type), language settings, software crash logs, and details about the device you used. This information 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 trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Scope, Legal Basis

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 companies and individuals who assist us in operating our platform, conducting our business, or delivering services to you. These parties have access to your personal data only as necessary to perform their functions and are contractually obligated not to use it for any other purpose. Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a different privacy policy. Legal Requirements: We may disclose your personal data where required to do so by law or in response to valid requests from public authorities, including courts or government agencies. Protection of Rights: We may disclose your personal data when we reasonably believe disclosure is necessary to protect our rights, your safety, or the safety of others, to investigate fraud, or to respond to a lawful government request. Consent: We may share your personal data with third parties for any other purpose with your explicit consent. Where your personal data is transferred outside your jurisdiction, we take appropriate steps to ensure it remains protected in accordance with this policy. You may request information about such transfers by contacting us directly.

We may share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis. At your request, we will share specific Personal Data with third-party trading platforms you designate. Your Personal Data shared in these instances will be governed by the privacy policies of those platforms. Your data may be shared with more than one trading platform. We may also share Personal Data with affiliated entities or business partners to support the development and improvement of our products and services. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities. We may share your Personal Data with prospective investors, acquirers, or lenders — whether in connection with the Company or any entity within its group — in the context of a transaction involving the transfer or sale of assets, or as part of any merger, restructuring, consolidation, or bankruptcy proceeding involving the Company or any group entity.

7. Third-Party Cookies and Services

We may work with third-party service providers, including advertising networks and analytics companies, to support our website. These providers may also use cookies or similar tracking 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 the content and services shown to you. 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 once you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognise you as a returning user, making it easier to access the website on subsequent visits.

Types of Cookies:

We may use them based on their purpose:

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 fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.
Your information will be shared with third-party trading platforms for 12 months. With your consent, we will continue sharing your data for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer needed.

9. Transfers of Personal Information to a Third-Party Country or International Organisation

10. Protecting Your Personal Data We take the security of your personal data seriously and implement appropriate technical and organisational measures to safeguard it against unauthorised access, loss, misuse, alteration, or destruction. No method of transmission over the internet or electronic storage is completely secure. While we apply commercially reasonable safeguards, we cannot guarantee absolute security. Access to your personal data is restricted to personnel and third parties who require it to perform their functions. Anyone with access is bound by confidentiality obligations. If you have reason to believe the security of your personal data has been compromised, contact us immediately using the details provided in this policy. Withholding certain personal data may prevent us from delivering our Services or granting you access to the website. Where this is the case, we will inform you at the point of collection. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable obligations. Once no longer needed, your personal data is securely deleted or anonymised.

We have implemented appropriate organizational and technical measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your personal data will be maintained without error, nor can we accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third-party access, or other causes beyond our control. Where legal or other obligations require it, we may be required to disclose your personal data to third parties, such as public authorities. In such circumstances, we have no control over how those third parties handle or secure your personal data. Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of any personal data you transmit to us online.

11. Links to Third-Party Websites

Our website contains links to third-party websites and applications. These are not under the Company's supervision, and we are not responsible for how those sites or apps collect or process Personal Data. This Policy does not apply to any actions taken through such third-party platforms.
Before accessing or using any third-party website or application, we recommend reviewing its privacy policy and exercising caution when providing Personal Data.

12. Changes to This Policy 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. Your continued use of our services after any changes take effect constitutes your acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed of any updates.

Before accessing any third-party websites or apps, read their privacy policies carefully. Only then should you decide whether to share any personal data with them.

13. Your rights regarding your personal information

You have the right to request that we verify the accuracy of Personal Data being collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope or type of processing applied to your Personal Data.
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 send a written request to the email address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. Where processing is confirmed, 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 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. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response.
Right to rectification
The Company will correct inaccurate Personal Data upon request. 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 no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) Personal Data is unlawfully processed; or (f) Personal Data must be erased 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 claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, 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 the Personal Data you have provided to the Company in a structured, commonly used format.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising this right does not affect your right to erasure, nor does it infringe on the rights or freedoms of others.
Right to object
You may object at any time 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 interests. Where you object, the Company will cease processing unless it can demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or where processing is necessary to establish, exercise, or defend legal claims.
Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.
Right to withdraw consent
You may withdraw your consent to our processing of 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 the relevant supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to uphold the fundamental rights of individuals in relation to 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, this period may be extended by up to two months depending on the complexity and volume of requests. 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 your rights under section 13 will be supplied at no cost. Where requests are unfounded or excessive, particularly where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person submitting a request, the Company may request additional information to confirm identity.