Privacy Policy

We are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store information you provide through the website https://marlinvestara.com (the Marlin Vestara).
The following principles apply:

We want you to make informed decisions about how your Personal Data is used and processed. We use a range of methods to keep you appropriately informed, and where specific details are required, we will provide them at the relevant time. We are also happy to address any questions you have regarding applicable legal limitations.

1. The Scope?

This policy describes the types of personal data Marlin Vestara collects about 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. A person is considered identifiable if they can be recognised directly or through a combination of additional information we hold or can reasonably access.
"Processing" refers to any operation involving personal data, including its collection, organisation, storage, and management.
Our services are intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that we hold data belonging to a person under 18, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. Depending on the context, we may request this information directly from you, gather it by analysing how you use our services or channels, or receive it from our third-party partners.

3. You are not required to share personal information with us, though doing so may affect the services we can provide or your ability to access the website.

Providing personal data is not mandatory. However, choosing not to share certain personal data 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 from you:

This includes information collected automatically when you use our services: your online activity log, traffic data (including IP address, access dates, and access times), language settings, software crash reports, browser type, and device information. This data 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 you provide directly 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 under the following circumstances. Service Providers. We work with trusted third-party service providers who support our operations. These parties process personal data on our behalf and are contractually required to handle it securely and in accordance with applicable data protection standards. Business Transfers. If we undergo a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We will notify you in advance where required. Legal Obligations. We may disclose your personal data to law enforcement, regulatory authorities, or other third parties when required by law or when necessary to protect our legal rights, prevent fraud, or ensure the safety of our users. Third-Party Links. Our website may contain links to third-party websites or services. We are not responsible for their privacy practices and encourage you to review their privacy policies directly. Consent-Based Sharing. In cases not covered above, we will share your personal data with third parties only with your explicit consent. We do not sell your personal data to third parties. Any sharing of personal data is carried out with appropriate safeguards in place to protect your information.

We may share your Personal Data with third-party service providers who support our operations, including hosting and storage providers and user experience analytics services. Upon your request, we will share specific Personal Data with third-party trading platforms you designate. In such cases, your Personal Data will be handled in accordance with the privacy policies of those platforms. Your Personal Data may be shared with more than one trading platform. We may also share Personal Data with affiliated entities or business partners where doing so supports 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 to the Company or any entity within our group of companies in connection with a proposed or completed transaction, including an asset transfer or sale, merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

7. Third-Party Cookies and Services

We may engage third-party services, such as advertising providers and analytics companies, on our website. These companies may also use cookies or similar 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 products and services shown to you. Cookies are also used for statistical and analytics 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 recognise you as a returning user and allow you to resume your experience seamlessly.

Types of Cookies:

We may use them according to 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 fulfil 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 a period of 12 months. With your consent, this sharing will continue for a further 12 months.
We periodically review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Data to a Third Country or International Organisation

10. Protecting Your Personal Data We take the security of your personal data seriously and have put in place appropriate technical and organisational measures to protect it against unauthorised access, loss, misuse, alteration, or disclosure. While we work to safeguard your personal data, no method of transmission over the internet or electronic storage is entirely secure. We cannot guarantee absolute security, but we continuously review and update our security practices to address evolving risks. Access to your personal data is restricted to employees, contractors, and third parties who have a legitimate need to process it. All such parties are bound by confidentiality obligations. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.

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 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, unauthorised third-party access, or other causes beyond our control.
Where legal or regulatory obligations require it, we may be required to disclose Personal Data to third parties, including public authorities. We have no control over how such third parties handle your Personal Data in those circumstances.
No data transmission over the internet can be guaranteed as fully secure. We cannot ensure the security of Personal Data you transmit to us online.

11. Links to Third-Party Websites

Our website may contain links to third-party websites and applications. These are not under the Company's supervision, and we are not responsible for how such sites or apps collect or process Personal Data. This Policy does not apply to any actions taken through third-party sites or applications.
Before accessing or using any third-party site or app, we recommend reading its privacy policy carefully. We also advise caution when providing any Personal Data to third parties.

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. We encourage you to review this Policy periodically to stay informed about how we protect your information. Continued use of our services following any updates constitutes your acceptance of the revised Policy.

Before visiting any third-party website or app, read their privacy policy carefully. Only share personal data with them once you are satisfied with how they handle it.

13. Your rights regarding your personal information

You have the right to request that we verify the accuracy of Personal Data 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 information.
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 submit a written request to the email address below.
Access rights
The Company can verify that your Personal Data is being processed. If it is, you may 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. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If 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. 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 there is no other legal basis for processing; (c) you object, on grounds specific to your situation, to the processing of Personal Data based on legitimate interests pursued by us or a third party; (e) Personal Data has been 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 question 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 for the establishment, exercise, or defence of legal claims, for the protection of the rights of another person, 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 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. The right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You have the right, at any time, to object 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 on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is not necessary for the establishment, exercise, or defence of legal claims, we will cease processing.
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 the 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 a supervisory authority established by a Member State to protect 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 the rights described in this section 13 in relation to Personal Data concerning you.
We will respond to requests made under section 13 within one month of receipt. Where necessary, and depending on the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Subject to the provisions of section 13, information provided in response to your rights will be supplied free of charge. Where requests are manifestly 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 verify identity.