Privacy Policy

1. The Scope

1.1 This policy explains what types of Personal Data the Company collects from individuals and how it processes, shares with third parties, and secures that data.

1.2 This Policy concerns 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 are able to access.

1.3 Under this Policy, "processing" refers to any activity that involves the use or collection of Personal Data, including its management, structuring, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18 years old, nor do we knowingly allow such persons to use our services. If we become aware of any information we have gathered about children, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 When you access the service and channels, or visit our website, we collect Personal Data. In certain instances, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You aren't obliged to provide Us with any Personal Data. In some cases, however, you may choose not to supply Us with any Personal Data. This could prevent Us from offering the Services or stop users from accessing the website.

4. What Personal Data We Collect

4.2 The information you collect is not private and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to enable trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 The company processes your Personal Data for the purposes set out in this section, and on the legal basis that applies to it.

5.3 Contact Us via email for more details about the processing required to protect the legitimate interests.

5.4 Below are the reasons 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 companies that provide services to us, such as hosting and storage providers, IP address information, as well as analysis of user experiences.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In these cases, we will provide the Personal Data you have given Us to those third-party trading platforms. The use of your Personal Data is then governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This gives the Company the resources it needs to enhance and improve the products and services it provides to its customers.

6.4 Where it is necessary to protect the rights or assets of third parties, The Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in the group, where such a transaction takes place (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 of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertising providers on our website or analytics companies. These companies may also use cookies or similar technology.

7.2 Cookies are small text files stored 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 improve your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time, until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and allow you to return to the site.

7.5 However, please be aware that some or all of the Website's functions and features may not work as you expect if this happens.

Online Tracking Notice: This service does not currently respond to do-not-track signals.

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer where permitted by law, regulations, policies, and applicable orders.

8.2 We'll share your information with third-party trading platforms for a period of 12 months. If you agree to this, we'll continue sharing your data for a further 12 months.

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

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country or to international organisations). Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 The Company can provide details about the security measures used to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@harborwyn-ai.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. Nor can we be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Where legal or other obligations beyond our control apply, we may be required to share your Personal Data with third parties, such as public authorities. In these situations, we cannot control the level of security applied to your Personal Data by those third parties.

10.4 Personal Data cannot be transmitted over the web in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to actions taken through such sites or apps.

11.2 Before accessing or using any third-party websites or apps that We recommend, please read their privacy policies. We also suggest that you provide any Personal Data to them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If we make changes, we will notify you by posting the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, We will aim to notify you through the methods we consider appropriate and will publish an announcement on our website.

12.3 Unless otherwise specified, any amendments will take effect once the revised Policy is published.

13. Your Rights

13.1 You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete all Personal Data we no longer require. You may also limit the scope of how your personal information is processed.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide regarding your Personal Data. To exercise any of these rights, you may send an email to the address below.

13.3 Access rights The Company can confirm whether Personal Data about you is being processed. If it is, 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. The data will be made available electronically if you request it. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request adversely affects the rights and freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.

13.4 Right to rectification The Company may 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 the processing.

13.5 Right to Erasure The following reasons apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis to process; (c) you object at any time, for a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued either by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be removed to meet a lawful obligation of the company. This right does not apply where the processing is necessary (a) to fulfil an obligation imposed by law that is required to be processed under European Union law or Member State law; or (b) to create, exercise or defend legal rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you can ask the Company to limit how it processes your Personal Data. If you request that Personal Data be restricted, that Personal Data may only be kept where you give consent, where it is needed to create, exercise or defend legal rights, to protect the rights of another natural person, or where there is a reason of significant public interest 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 on a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. The rights you hold under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not interfere with the rights or freedoms of others.

13.8 Right to challenge You may object at any time to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based on those legitimate interests. If we can establish compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can show that these grounds are outweighed by your rights, freedoms, or interests, or by the exercise, establishment, or defence of legal rights. In relation to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw your consent for Us to process your Personal Data at any time. This will not affect the legality or lawfulness of any processing carried out under your consent before its withdrawal. You are entitled to lodge a complaint with your supervising authority. You may appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights concerning your Personal Data, as detailed in this section 13.

13.10 In line with your rights under section 13 of this agreement, we will provide the requested information within one month of receiving your request. Depending on the nature of the request and the number of requests received, this period may be extended by up to two months. If an extension is required, we will notify you of it and the reasons within one month of receiving your request.

13.11 Provided it does not conflict with the provisions of section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. Where a request is unjustified or excessive, particularly if it is repeated, we may charge a reasonable amount to cover the administrative costs of providing the information or carrying out the action requested. We may also decline to act.

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