Privacy Policy Last updated: 24/02/2024

We, referred to as "Us" or "Our," are committed to safeguarding your Personal Data and privacy.

This Privacy Policy has been drawn up to inform you of how we manage, collect, store, and use the information you supply in connection with the website Wartomex (the "Website").

We pledge to honour the following principles:

•To ensure openness in the collection and processing of your Personal Data:

We place priority on ensuring you are kept fully informed, allowing you to reach well-judged decisions regarding the use of your Personal Data on our Website or when engaging in trades with a third-party trading platform. To achieve this, we apply a range of strategies and methods to supply you with relevant details on how your Personal Data is processed, ensuring this information is delivered accurately and in a timely fashion.

Furthermore, if it becomes necessary for us to supply you with specific information, we will ensure it is delivered at the appropriate time and place.

We are also keen to address any queries you may have and to provide any clarification you require, subject to legal limits. For this purpose, feel free to reach out to us by sending an email to: [email protected]

•To process your Personal Data solely for the purposes set out in this Policy:

The purposes for which we may process your Personal Data include, among others, making the Website available to you and connecting you with third-party trading platforms (the "Services"), to enhance your experience on the Website, to refine the Services (including the Website), to safeguard Our rights and interests, to carry out business and administrative activities that support the provision of the Services to the Website users, and/or to comply with any legal and/or regulatory obligations.

In addition, We will process Personal Data about you to better grasp your individual needs and preferences.

• To set aside substantial resources in honouring your rights regarding your Personal Data:

We dedicate significant resources to enable you to exercise your rights as a data subject. Accordingly, you are welcome to reach out to Us at any time should you wish to review Personal Data about you, have Us amend it, delete it, stop using it for specific purposes or altogether, or transfer it to you or a third party. We will act on your requests in line with the law.

•To safeguard Personal Data about you:

While We cannot promise absolute security of the Personal Data about you, We assure you that We use and will continue to use a broad set of methods and measures aimed at ensuring the Personal Data about you is protected.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy sets out the types of Personal Data the Company gathers about individuals, along with the methods of its collection, use, sharing with third parties, protection, processing, and so on.

In this Policy, "Personal Data" refers to any information relating to an identified or identifiable individual. An identifiable individual is someone who can be identified, directly or indirectly, in conjunction with additional information that We possess or have access to.

In this Policy, the "processing" of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organisation, structuring, storage, modification or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

Our Services are designed for a general audience and are not aimed at children under the age of 18. We do not knowingly gather or request information from anyone under 18 nor knowingly permit such individuals to access our Services. If We become aware that we have gathered information about a child, We will take reasonable steps to remove such information promptly.

2. When Do We Collect Personal Data About You?

We gather Personal Data about you whenever you use the Services, engage with the service channels, and visit the Website. Sometimes, you will supply Us with the Personal Data directly, and in other cases, We will gather the Personal Data by examining and analysing your interaction with Our Services and/or Our service channels or receive your data from our third-party partners.

3. No Obligation To Provide Personal Data To Wartomex And Its Implications

You are not obliged to provide Us with any Personal Data about you. However, in certain situations, not providing such Personal Data will prevent Us from delivering the Services to you, will hinder your use of the Website, and/or may cause the Services and the Website to malfunction.

4. What types of Personal Data do We collect? Personal Data We collect upon each visit to the Website:

This information includes online activity logs, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports, and type of browser used, as well as information regarding the device you used. Some of this information may not personally identify you, and therefore may not be regarded as Personal Data.

Personal Data We receive from you: any Personal Data you supply to Us voluntarily when interacting with a third-party trading platform through Us.

Personal Data You specifically supply for submission to third-party platforms to facilitate trading: This includes your full name, phone number, and email address.

5. The Objectives for Processing Personal Data and Their Legal Foundations

Wartomex handles your Personal Data for one or more of the purposes detailed in this section, each backed by the appropriate legal grounds.

Wartomex will not process your Personal Data unless there is a legitimate legal basis for such actions. The legal bases on which Wartomex may handle your Personal Data include:

• You have given consent for the processing of your Personal Data for specific purposes. This applies when you deliberately share your information through the Website, allowing us to submit it to a third-party trading platform.
• Processing is required to serve the legitimate interests pursued by Wartomex or a third party. For example, this may include enhancing our Services or managing legal claims.
• Processing is necessary to fulfil a legal obligation to which Wartomex is subject.

If you need further clarification on how processing your Personal Data serves the legitimate interests of Wartomex or another party, please don't hesitate to contact us via email at any time.

Below, we outline the reasons why we may process your Personal Data, along with the legal bases for these activities:

	Objective	Legal Foundation
1	To forward your information to third parties at your request for engaging in digital and trading activities. We may gather Personal Data about you to forward it to third parties, should you explicitly request this action.	You have given consent for the processing of your Personal Data for one or more specified objectives.
2	To address your enquiries, requests, and/or concerns Processing of your Personal Data is necessary to address any enquiries you may have regarding your use of our Services.	Processing is required for the legitimate interests pursued by the Company or a third party.
3	To fulfil any legal responsibilities or court and administrative directives We handle your Personal Data to ensure adherence to our various legal responsibilities.	Processing is essential to meet a legal requirement that the Company is obliged to follow.
4	To enhance Our Services We may use your Personal Data to refine Our Services. This processing includes, among other things, analysing crash logs or any other malfunction reports related to the Services.	Processing is essential for the pursuit of legitimate interests by the Company or a third party.
5	To prevent fraudulent activities and misuse of Our Services	Processing is essential for the pursuit of legitimate interests by the Company or a third party.
6	To carry out and sustain various activities that support the delivery of Our Services Such operations include back-office tasks, business development initiatives, strategic planning, oversight processes, and more.	Processing is required to serve the legitimate interests pursued by the Company or a third party.
7	To conduct analyses, including statistical evaluations We apply a variety of analytical techniques, including statistical methods, to inform decisions on a range of matters.	Processing is required to serve the legitimate interests pursued by the Company or a third party.
8	To safeguard Our and third parties' interests, rights, and assets, including the initiation, exercise, or defence of legal claims We may handle your Personal Data to defend Our interests, rights, and assets, or those of third parties, in compliance with any law, regulation, or agreement, including any of Our terms, conditions, and policies.	Processing is required to serve the legitimate interests pursued by the Company or a third party.

6. Transfer Of Personal Data To Third Parties

Wartomex may also disclose your Personal Data to third-party service providers who assist us with storage, hosting, IP address information, user experience analysis, research, and other analytical, technical, and diagnostic services.

Additionally, if you specifically request, we can transmit certain Personal Data about you to third-party trading platforms. In such cases, we will share the information you supply for this purpose with those third parties, and they will handle your Personal Data according to their privacy policies. We may share your Personal Data with several third-party trading platforms.

Wartomex may also share your Personal Data with its affiliated entities and business partners, who provide resources that strengthen and elevate the quality of services and products we offer to our users.

We may disclose your Personal Data to governmental, local, official, and regulatory bodies if such disclosure is necessary to protect our interests, rights, and assets, as well as those of third parties, including the initiation, exercise, or defence of legal claims.

Furthermore, we may release Personal Data about you to potential buyers, investors, or lenders of Wartomex or any company within our group, or during any similar transaction (such as asset sales), or in connection with any merger, reorganisation, consolidation, or bankruptcy of Wartomex or any related company.

7. Cookies and Third Party Services

We might use certain third-party services, such as analytics companies or advertisement providers on our Website, which may also employ cookies or other technologies. These practices and providers are governed by their own policies.

A cookie, which is a small text file, is installed on the device you use to visit or access the Website. These cookies enable the collection of information about you and your behaviour, to enhance your user experience by remembering your preferences and settings, and by tailoring products and services that may capture your interest. Cookies may also be used to gather statistics and perform analytics.

Some cookies we may use are session cookies, which are temporarily downloaded to your device and remain active until you close your web browser. Others are persistent cookies, which stay on your device after you stop browsing the Website, helping the Website recognise you as a returning visitor.

Types of cookies:

The cookies we may use are categorised based on their function as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are indispensable for enabling you to navigate the Website and access features you have requested. They ensure delivery of our content, products, and services you seek. Such cookies are crucial for your device to download or stream information, allowing smooth navigation through the Website, use of its features, and revisiting previously accessed pages.	These cookies collect personal data about you, such as your username and last login date, and confirm your login status on the Website. These cookies are automatically removed once you close your web browser (session cookies).
Functionality Cookies	These cookies help us recognise you when you return to the Website, enabling us to remember your selections and preferences.	These cookies remain active even after your browser is closed, lasting until they reach their set expiry time.
Performance Cookies	These cookies are essential for gathering aggregated statistics about the Website's performance, helping in its testing and enhancement to deliver a superior user experience. They also allow us to perform analytical functions on the Website.	These cookies gather anonymised data that cannot be traced back to any identified or identifiable individual. The validity of these cookies varies; some are erased when you close your browser, while others persist indefinitely.

Blocking and Removing Cookies

You can adjust your browser settings to block and remove some or all cookies. Below are links with instructions for doing this in some of the most widely used web browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that if you proceed, certain features and functionalities of the Website might not operate as expected.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

Wartomex will retain your Personal Data as long as necessary to fulfil the purposes outlined in this Policy or as required by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for a 12-month period and, subject to your consent, may extend this for a further 12 months.

To ensure that your Personal Data is not held longer than necessary, we regularly review the data we retain to determine whether any can be deleted.

9. Transfers of Personal Data To A Third Country Or An International Organisation

Your Personal Data may be transferred to a third country (i.e., outside of your jurisdiction) or to international organisations. In such cases, Wartomex will implement appropriate safeguards to ensure the protection of your Personal Data and provide enforceable data subject rights and effective legal remedies.

If you reside in the EEA (European Economic Area), please note that these protections and safeguards will be in place if any of the following conditions are met:

• The transfer is directed to a third country or an international organisation recognised by the EU Commission as offering an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 (commonly known as the "GDPR").
• The transfer is carried out under a legally binding and enforceable agreement between public authorities or bodies as outlined in Article 46(2)(a) of the GDPR; or
• The transfer complies with standard data protection clauses adopted by the EU Commission in line with Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

If you're interested in learning about the safeguards we use to protect the Personal Data transferred to a third country or an international organisation, please reach out to us via email at: [email protected]

10. Protection Of Your Personal Data

We take the implementation of appropriate technical and organisational measures seriously to ensure a high level of security for Personal Data, considering the risks associated with processing, especially from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we strive for excellence, we cannot promise error-free performance regarding the privacy of your Personal Data. We disclaim any liability for indirect, incidental, consequential, or punitive damages related to the use or release of your Personal Data, including but not limited to, disclosure of Personal Data due to transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

In some cases, legal or other obligations beyond our control may require us to transfer your Personal Data to third parties, entities such as public authorities. In these scenarios, our control over the protection level offered to your Personal Data by such third parties is limited.

The transfer of Personal Data over the internet cannot be completely safeguarded. Consequently, Wartomex cannot guarantee the security of your Personal Data when it is transmitted over the internet to us.

11. Links to Third-Party Websites

The Website may contain links to websites and/or applications operated by third parties. Wartomex does not oversee these websites and applications, nor the gathering and/or processing of your Personal Data by them. We hold no responsibility for these websites and applications or their privacy and data protection policies and practices. This Policy does not govern any activities conducted through such websites and/or applications.

Whenever you visit these third-party websites and/or applications, we advise you to thoroughly examine their privacy policies before using them and before sharing any of your Personal Data.

12. Your Rights Regarding Your Personal Data

Broadly, you have the right to request that we confirm whether we are collecting Personal Data about you, to review this data, to correct any inaccuracies, and to delete Personal Data no longer needed by us. You can also limit your consent to specific processing of your Personal Information.

If you are a resident of the EEA, please review this section:

You have the following rights concerning your Personal Data. To exercise these rights, you may send a request to the following email address:

Right of Access

You have the right to obtain from Wartomex confirmation as to whether your Personal Data is being processed and, if so, to access the Personal Data along with the following details: (1) the objectives of processing; (2) the types of Personal Data involved; (3) the recipients or groups of recipients to whom the Personal Data has been or will be shared, particularly those in countries outside the European Economic Area (EEA) or with international organisations; (4) if feasible, the planned duration for storing the Personal Data, or if not feasible, the criteria used to determine that duration; (5) the existence of the right to request from Wartomex the correction or deletion of Personal Data or the limitation of its processing, or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data was not gathered directly from you, any available information regarding its origin; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organisation, the appropriate safeguards regarding the transfer.

Wartomex will provide a copy of the Personal Data undergoing processing and may impose a reasonable fee for any additional copies you request. If your request is made electronically, and unless you specify otherwise, the information will be provided in a commonly used electronic format.

The right to obtain a copy of the Personal Data must not infringe on the rights and freedoms of others. Therefore, if the request compromises the rights and freedoms of others, Wartomex may choose not to fulfil your request or to do so in a restricted manner.

Right to rectification

You are entitled to have Wartomex correct any inaccurate Personal Data about you. Considering the purposes of processing, you have the right to have incomplete Personal Data about you completed, possibly by providing a supplementary statement.

Right to erasure

the following grounds apply: (a) the Personal Data is no longer needed for the purpose it was gathered or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your specific situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data concerning you must be deleted to comply with a legal obligation under European Union or Member State law applicable to the Company.

This right does not apply if the processing is necessary (a) to comply with a legal obligation requiring processing under European Union or Member State law to which the Company is subject; or (b) for establishing, exercising, or defending legal claims.

Right to Restrict Processing

You have the right to request that the Company restricts the processing of your Personal Data under the following circumstances: (a) if you dispute the accuracy of the Personal Data, for a period that allows the Company to verify its accuracy; (b) if the processing is unlawful and you oppose erasure, opting instead to restrict its use; (c) if the Company no longer requires your Personal Data for processing purposes, but you need it to establish, exercise, or defend legal claims; (d) if the processing is necessary for the legitimate interests pursued by the Company or a third party, unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for establishing, exercising, or defending legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent related to such marketing.

Should the processing of your Personal Data be restricted at your request, such data, apart from storage, will only be processed with your consent or for establishing, exercising, or defending legal claims, protecting the rights of another natural or legal person, or for significant public interest reasons of the European Union or a Member State.

Right to Data Portability

You are entitled to receive your Personal Data, which you have supplied to the Company, in a structured, commonly used, and machine-readable format. Additionally, you have the right to transfer this data to another entity if the processing is based on your consent or a contract to which you are a party, and the processing is carried out by automated means.

When you exercise your right to data portability, it's possible to have your Personal Data transferred directly from the Company to another organisation, provided it can be done technically. This right doesn't interfere with your or the Company's rights to data deletion. Moreover, exercising this right should not adversely impact the rights and freedoms of others.

Right to Withdraw Consent

You have the ability to withdraw your consent for us to process your Personal Data at any time, without affecting the lawfulness of any processing carried out before the withdrawal.

Right to Object

You may object to the processing of your Personal Data at any time, especially if it pertains to your particular situation, and when the processing is based on the legitimate interests of the Company or a third party. This includes any profiling conducted on these grounds. Once you object, we will cease processing your Personal Data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

Additionally, you can object to the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to lodge a complaint with a supervisory authority

You are entitled to file a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights and freedoms of individuals concerning the processing of Personal Data within the European Union.

Your rights concerning your Personal Data as detailed in this section 13 may be limited by European Union or Member State law to which the Company is subject.

We will provide you with the requested information as per your rights detailed in this section 13 promptly and within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested according to your rights detailed in this section 13 will be provided at no charge, unless specified otherwise in this section 13. Where requests are manifestly If a request is considered unreasonable or excessive, particularly due to its repetitive nature, we may either (a) impose a reasonable fee, reflecting the administrative expenses incurred to provide the information, communication, or action requested; or (b) decline to fulfil the request.

Wartomex might ask you to provide additional details necessary to verify your identity to process your request as per your rights outlined in this section 13, especially if there are reasonable doubts regarding the identity of the individual making the request.

13. Updates To This Policy

We reserve the right to amend this Policy periodically. Whenever changes are made, we will inform you by posting the revised Policy on the Website. Moreover, for significant updates, we will endeavour to notify you through communication methods deemed reasonably effective to inform you of such changes, and by posting a notice on the Website. Unless otherwise specified, all modifications will become effective once the updated Policy is published on our Website.