Privacy Policy

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects from natural persons, and how that data is processed, shared with third parties, and secured.

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 indirectly by reference to additional information that we hold or can access.

1.3 Under this Policy, "processing" means any operation that uses or collects 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, and we do not knowingly permit such persons to use our services. If we learn that we hold information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you use our service and channels or visit our website. In certain instances, we may request your Personal Data directly from you.

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 are not obliged 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

4.2 The information we collect is not personal data 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 to a third party's online trading platform through Us.

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

5. Legal Basis and Reasons for Processing of Personal Data

5.1 We process your Personal Data for the purposes set out in this section, on the legal basis that applies to it.

5.3 Email us for more details about the processing necessary to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party providers that deliver services to us, such as hosting and storage providers, IP address information, and 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 instances, we will provide the Personal Data you supply to us to those third-party trading platforms. Your Personal Data may be shared with multiple trading platforms, and its use is governed by their respective privacy policies.

6.3 The Company may share Personal Data with related entities or business partners. This provides the resources needed to develop and improve the products and services offered to its customers.

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

6.5 We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within 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 placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits 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 stored on your device and last only until you close your browser. Others are persistent cookies, which remain on your device for a period after you close your browser. These help the Website recognise you as a returning user and make it easier to return to the Website.

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

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 purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

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

8.3 We regularly review the Personal Data we hold to confirm whether it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to a third country or to international organizations. Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can assert their rights and access effective legal recourse.

9.3 We can provide details about the security measures used to protect your Personal Data transferred to third-party countries or international organisations. Email us at: support@dunecapitora.com

10. Security of Personal Data

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

10.2 We cannot guarantee 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 disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's control. We are not responsible for the collection or processing of Personal Data by these sites or applications. This Policy does not apply to any actions taken through them.

11.2 If you access any third-party websites or apps, we recommend reading their privacy policies before deciding to use them, and before providing any Personal Data to them.

12. Modifications to This Policy

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

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

12.3 Unless explicitly stated otherwise, any amendments take effect once the revised Policy is published.

13. Your Rights

13.1 You have the right to request verification of the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the scope and types of processing applied to your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, please send an email to the address below.

13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, you can 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 additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request adversely affects the rights and freedoms of another person, the Company may refuse to comply with it or limit how far it fulfils the request.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer needed for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil a legal obligation that requires processing 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 ask the Company to restrict its processing. Where you request such a restriction, the Personal Data may only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights of another natural person, or for reasons of substantial public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is automated and 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 this Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure, nor does it interfere with the rights or freedoms of others.

13.8 Right to object You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we establish compelling legitimate grounds for processing, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests override those grounds, or where the processing relates to 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 Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You also have the right to lodge a complaint with your supervisory authority. You may submit such a complaint to a supervisory authority established by a member state to protect the fundamental rights of individuals concerning the processing of Personal Data within the European Union. The laws of the European Union and Member States may restrict your rights regarding Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. We will notify you of any such extension, along with the reasons, within one month of receiving your request.

13.11 Where it does not conflict with the provisions of section 13 of the law, information requested under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where it is repeated, 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 the request.

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