Politique de confidentialité

1. Le périmètre

This policy describes the types of personal data the Company collects from individuals, how that data is processed, shared with third parties, and secured.

1.2 This Policy applies to information relating to an identified or identifiable individual. An identifiable individual is one who can be identified directly, or indirectly through additional information we hold or can reasonably access.

1.3 The Policy defines "processing" as any activity involving the use or collection of Personal Data, including its management, structuring, and storage.

Our services are intended for a general audience and are not designed for individuals under the age of 18. We do not knowingly solicit or collect personal information from anyone under 18, and we do not knowingly permit such individuals to use our services. Any information relating to a minor that comes to our attention will be deleted promptly.

2. Quelles données personnelles détenons-nous sur vous

When you access our services and channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide Personal Data directly.

In some cases, we collect your Personal Data by analyzing how our Services and service channels are used, or by receiving your information from third-party partners.

3. Aucune obligation de divulguer des informations personnelles

You are not required to provide us with personal data. However, in some circumstances, choosing not to may prevent us from delivering our Services or granting you access to the website.

4. Quelles données personnelles nous collectons

4.2 The information we collect is non-personal and cannot be used to identify you.

4.3 Personal data you provide to us: any personal data you voluntarily share with us when connecting to a third-party online trading platform through our services.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions includes your full name, address, phone number, and email address.

5. Base juridique et finalités du traitement des données personnelles

5.1 Your personal data is processed by the company for the purposes described in this section, in accordance with the applicable legal basis.

For details about the processing carried out to safeguard legitimate interests, please contact us by email.

5.4 Ci-dessous figurent les motifs et les bases juridiques sur lesquels nous pouvons nous appuyer pour traiter les informations que vous nous communiquez :

6. Transfert des données personnelles à des tiers

6.1 The Company may also share personal data with third-party service providers, including hosting and storage providers, IP address information services, and user experience analytics providers.

6.2 You may also request that we transfer certain personal data about you to third-party trading platforms. In such cases, we will share the personal data you have provided to us directly with those platforms. Your personal data will be subject to their respective privacy policies and may be shared with more than one third-party trading platform.

6.3 The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources needed to develop and improve the products and services offered to its clients.

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 of the Company or any other group company, in connection with a potential transaction (including the transfer or sale of assets belonging to the Company or any other group company), or in connection with any merger, restructuring, consolidation, or insolvency involving the Company or any other group company.

7. Cookies et services de tiers

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

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 personalize products and services relevant to you. Cookies are also used for statistical and analytical purposes.

Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognize you as a returning user and allow you to return to the site without starting fresh.

Please note that disabling cookies may cause some or all Site features to not function as expected.

Online Tracking Notice: This service does not currently honour "do not track" signals.

8. Conservation des données personnelles

We will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for a longer period where permitted by applicable law, regulations, or regulatory orders.

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is no longer needed.

9. Transferts internationaux

9.1 Your personal data may be transferred to other countries, including third-party countries or international organizations. The Company takes all necessary measures to protect your personal data and ensures that those who process it can uphold your rights and access effective legal remedies.

9.3 The Company can provide information about the security measures it implements to protect your personal data transferred to third countries or international organizations. To request this information, email: support@cumulerance.com

10. Sécurité des données personnelles

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including against accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that 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, without limitation, Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other cause beyond our reasonable control.

10.3 In certain circumstances, we may be legally or otherwise required to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over 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. We cannot guarantee the security of personal data you transmit to us online.

11. Liens hypertextes vers des sites web tiers

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 they collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.

When accessing any third-party website or application, review its privacy policy before using or sharing personal data with it.

12. Modifications de cette politique

12.1 This Policy may be updated at any time. When changes are made, the revised Policy will be posted on our website.

12.2 When we make significant changes to this Policy, we will notify you through appropriate channels and post an announcement on our website.

12.3 Unless otherwise specified, any changes take effect upon publication of the revised Policy.

13. Vos droits

You have the right to request that we verify the accuracy of the Personal Data we hold about you, correct any inaccuracies, and delete any Personal Data we no longer need. You may also restrict the types of processing applied to your personal information.

If you reside in the EEA, please refer to this page. These rights apply to the personal data you provide to us. To exercise your rights, send an email to the address below.

13.3 Right of Access You may request access to the personal data we hold and process about you. Upon a valid request, we will provide an electronic copy of the personal data being processed. A reasonable fee may apply for additional copies. If you request the data in electronic format, it will be provided accordingly. The right of access must not infringe on the rights and freedoms of others. Where a request would adversely affect another person's rights or freedoms, we may refuse or limit its scope.

13.4 Right of Rectification The Company may correct inaccurate personal data. You have the right to request the completion of any incomplete personal data concerning you, taking into account the purpose of the processing.

13.5 Right to Erasure You may request erasure of your personal data in the following circumstances: (a) the personal data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and no other legal basis for processing exists; (c) you object, on grounds relating to your particular situation, to processing based on our legitimate interests or those of a third party; (e) the personal data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation applicable to us. 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.

13.6 Restrictions on Processing 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 in place, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is an important public interest ground 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 access 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 transfer does not prejudice the rights or freedoms of others.

13.8 Right to Object You have the right to object at any time to the processing of your personal data where that processing is based on the legitimate interests of the Company or a third party, including profiling based on those interests. Where we can 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 that processing. Regarding direct marketing, you have the right to object at any time to the processing of your personal data for that purpose.

13.9 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 on the basis of your consent prior to that withdrawal. You have the right to lodge a complaint with your applicable supervisory authority. You may file a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals with respect to the processing of Personal Data within the European Union. European Union and Member State laws may limit your rights regarding your Personal Data, as set out in this section 13.

13.10 We will respond to requests made under Section 13 of this agreement within one month of receipt. If necessary, this period may be extended by up to two additional months, depending on the nature and volume of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.

Under section 13 of the Act, information provided in response to your rights requests will be made available at no charge, unless an exception applies. Where a request is unfounded or excessive — particularly where it is repetitive — 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 on such a request.

If we have reasonable doubts about the identity of the individual who submitted your request, we may ask that person to provide satisfactory proof of identity.