Privacy Policy Last updated: 24/02/2024
We, “We”, “Us” or “Our are dedicated to safeguarding your Personal Data and ensuring your privacy.
This Privacy Policy has been designed to inform you about how We manage, collect, store, and utilize the information you provide in connection with the website (the “Website”).
We will adhere to the following principles:
•To be transparent in respect of the collection and processing of Personal Data about you:
We prioritize ensuring that you are always fully informed, enabling you to make well-informed choices regarding the use of your Personal Data on our Website or when initiating trades with a third-party trading platform. To achieve this, we employ a range of strategies and methods designed to offer you pertinent details on how your Personal Data is processed, ensuring this information is delivered accurately and timely.
In addition, if We find you are required to be provided with specific information, We will provide it to you at the appropriate time and place.
We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: support@
•To process Personal Data about you solely for the purposes outlined in the Policy:
The purposes for which We may process Personal Data about you include, inter alia, to make the Website available to you andprovide you with access to third-party trading platforms (the “Services”), to elevate your experience on the Website, enhance the Services (including the Website), protect Our rights and interests, perform business and administrative activities that support the provision of the Services to Website users, and/or comply with any legal and/or regulatory requirements.
Additionally, We will process Personal Data about you to understand your individual needs and preferences.
• To invest substantial resources to uphold your rights concerning your Personal Data:
We allocate significant resources to ensure you can exercise your rights as a data subject. Therefore, you may contact Us anytime you wish to review your Personal Data, have Us amend it, erase it, cease using it for specific purposes or altogether, or transfer it to you or a third party. We will fulfill your requests in accordance with the law.
•To safeguard your Personal Data:
While We cannot guarantee absolute protection of your Personal Data, We assure you that We use and will continue to use a wide array of methods and measures to ensure your Personal Data is secure.
Our Complete Privacy Policy
1. The Scope?
This Policy outlines the types of Personal Data the Company collects about individuals, and how it collects, uses, shares with third parties, secures, processes, etc.
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 in combination with additional information that We possess or have access to.
In this Policy, “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring,storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
Our Services are designed for a general audience and are not intended for children under the age of 18. We do not knowingly collect or solicit information from individuals under the age of 18 or knowingly permit such individuals to use our Services. If we become aware that we have collected information from a child, we will take reasonable measures to promptly delete such information.
2. When Do We Collect Personal Data About You?
We gather Personal Data about you whenever you use our Services, interact with our service channels, or visit our Website. Sometimes, you will provide us with Personal Data directly, and other times, we will collect Personal Data by analyzing your usage of our Services and/or service channels or receive your data from third-party partners.
3. No Obligation To Provide Personal Data To The Company And Its Implications
You are not required to provide us with any Personal Data. However, in certain situations, not providing such Personal Data may prevent us from offering you our Services, restrict your access to the Website, and/or cause malfunctions in the Services and the Website.
4. What types of Personal Data do We collect? Personal Data We collect upon each browsing onto the Website:
This information includes online activity logs, traffic information (including, but not limited to, IP address, time of access, date of access, web and mobile pages visited, language used, software crash reports, and type of browser used), and details regarding the device you used. Some of this information may not identify you personally, and therefore may not constitute Personal Data.
Personal Data We receive from you: Any Personal Data you provide to us voluntarily when interacting with a third-party trading platform through Miderglar App.
Personal Data You specifically provide for submission to third-party platforms for trading: This information encompasses your full name, telephone number, and email address.
5. The Purposes of Processing Personal Data and Their Legal Basis
Our Company processes your Personal Data for one or more of the purposes outlined in this section, adhering to the relevant legal basis.
The Company will not process Personal Data about you unless there is a legal foundation for such processing. The legal bases according to which the Company may process Personal Data about you include:
- You have given consent to the processing of your Personal Data for one or more specific purposes. This applies to instances where you explicitly provide your details through the Website, allowing us to submit them to third-party trading platforms.
- Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. For example, for the enhancement of Our Services, or for the exercise or defense of legal claims.
- Processing is necessary for compliance with a legal obligation to which the Company is subject.
Should you need further details on how the processing of your Personal Data aligns with the legitimate interests of our Company or a third party, please feel free to contact us via email at any time.
Below, we present a summary of the reasons we might process your Personal Data, along with the legal grounds for such activities:
| Purpose | Legal Basis | |
| 1 |
To provide your details to third parties upon your request for engaging in digital trading. We may gather Personal Data about you to share with third parties if you explicitly request us to do so. |
You have provided consent for the processing of your Personal Data for one or more specific purposes. |
| 2 |
To address your inquiries, requests, and/or complaints Processing your Personal Data is essential to respond to your inquiries regarding the use of our Services. |
Processing is necessary for the legitimate interests pursued by the Company or by a third party. |
| 3 |
To fulfill any legal obligations or comply with judicial or administrative orders We handle your Personal Data to meet our legal requirements. |
Processing is necessary to comply with a legal obligation that the Company must adhere to. |
| 4 |
To enhance Our Services We might utilize your Personal Data to enhance our Services. This includes processing crash logs or other malfunction reports related to our Services. |
Processing is necessary for the legitimate interests pursued by the Company or a third party. |
| 5 |
To prevent fraud and misuse of Our Services |
Processing is necessary for the legitimate interests pursued by the Company or a third party. |
| 6 |
To conduct and maintain various activities supporting the provision of Our Services Such activities encompass back-office operations, business development initiatives, strategic planning, oversight functions, and more. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
| 7 |
For the purpose of conducting analyses, including statistical analysis We employ a variety of analytical methods (including statistical tools) to inform our decision-making on various matters. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
| 8 |
To safeguard our interests, rights, and assets, as well as those of third parties, including initiating, exercising, or defending legal claims We may process your Personal Data to protect our interests, rights, and assets, or those of third parties, in compliance with applicable laws, regulations, or agreements, including any of our terms, conditions, and policies. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
6. Transfer Of Personal Data To Third Parties
We may share your Personal Data with third parties who provide us with essential services such as storage, hosting, IP address information, user experience analysis, and other analytical, technical, and diagnostic services.
Additionally, if you specifically request, we can transmit certain Personal Data to third-party trading platforms. In these instances, the data you provide will be shared with these third parties, and their use of your Personal Data will adhere to their own privacy policies. We might share your Personal Data with multiple third-party trading platforms.
Miderglar App may also share your Personal Data with related entities and business partners that supply resources to enhance and improve the services and products we offer to our users.
We may disclose your Personal Data to governmental, local, official, and regulatory authorities if required, or to protect our interests, rights, and assets, as well as those of third parties, including the initiation, exercise, or defense of legal claims.
Furthermore, we might disclose your Personal Data to potential buyers, investors, or lenders of Miderglar App and/or any company within our corporate group. This could occur during transactions such as asset sales, mergers, reorganizations, consolidations, or bankruptcies involving Miderglar App and/or any company within our corporate group.
7. Cookies and Third Party Services
We may employ third-party services, like analytics companies or advertisement providers, on our website. These services may use cookies or other technologies, and their practices are governed by their own policies.
A cookie (a small text file) may be installed on the device you use to visit or access our website. Cookies help collect information about you and your behavior to...
enhance your user experience, remember your preferences and settings, and personalize and provide you with products and services that might catch your interest. Additionally, cookies may be employed to gather statistics and perform analytics.Some of the cookies we may use are session cookies, which are temporarily downloaded to your device and last until you close your web browser. Others are persistent cookies, which remain on your device after you stop browsing the Website and help the Website recognize you as a returning visitor when you come back.
Types of cookies:
The cookies we may use are categorized based on their functionality as follows:
| Type of Cookie | Purpose | Additional Information |
| Strictly Necessary Cookies |
These cookies are crucial to enable you to navigate the Website and utilize features you have requested. They are used to deliver our content, products, and services that you have asked for. Such cookies are vital to assist your device in downloading or streaming information, allowing you to navigate the Website, use its features, and revisit pages you have previously viewed. |
These cookies collect Personal Data about you, such as your username and last login date, and recognize you as being logged in to the Website. These cookies are removed when you close your web browser (session cookies). |
| Functionality Cookies | These cookies help us recognize you when you return to the Website and allow us to remember your choices and preferences. | These cookies persist even after you close your web browser, lasting until their designated expiry time. |
| Performance Cookies | These cookies are utilized to provide aggregated statistics regarding the Website's performance and to test and enhance that performance, ensuring a superior user experience. Additionally, they enable us to perform analytical functions on the Website. |
These cookies collect anonymized data that does not relate to an identified or identifiable individual. The validity of these cookies varies; some are deleted when you close your browser, while others remain indefinitely. |
Blocking and Removal of Cookies
You can modify your browser settings to block and delete some or all cookies. Below are links to instructions for some of the most popular web browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please be aware that altering these settings may cause some or all of the Website's features and functionalities to 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
Miderglar App will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or for a longer period as required by applicable laws, regulations, policies, and orders.
We will share your information with third-party trading platforms for a period of 12 months, and with your consent, this may be extended for an additional 12 months.
To ensure your Personal Data is not kept longer than necessary, we periodically review the data we retain to determine if any can be deleted.
9. Transfers of Personal Data To A Third Country Or An International Organization
Your Personal Data may be transferred to countries outside of your residence or to international organizations. In such cases, Miderglar App will implement appropriate safeguards to protect your Personal Data and ensure enforceable data subject rights and effective legal remedies are available.
If you are a resident of the EEA (European Economic Area), please note that these protections and safeguards will be provided if any of the following conditions are met:
- The transfer is directed to a third country or an international organization that the EU Commission has deemed to provide an adequate level of protection for the Personal Data transferred to it, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is based on a legally binding and enforceable instrument between public authorities or bodies, pursuant to Article 46(2)(a) of the GDPR; or
- The transfer follows standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. You can view these clauses on the EU Commission's website at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
You may request the Company to provide details on the safeguards it employs to protect your Personal Data when transferred to a third country or an international organization by sending an email to: support@
10. Protection Of Your Personal Data
We implement appropriate technical and organizational measures to ensure a suitable level of security for Personal Data, considering the risks presented by processing, especially from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data transmitted, stored, or otherwise processed.
We cannot guarantee, nor do we represent, that there will be error-free performance regarding the privacy of your Personal Data, and we will not be liable for any 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, unauthorized third-party access, or other causes beyond our reasonable control.
We may be required, due to legal or other obligations beyond our control, to transfer your Personal Data to third parties,such as public authorities. In these situations, we have limited control over the protection level provided to your Personal Data by such third parties.
Any transfer of Personal Data over the internet cannot be completely secured. Therefore, the Company cannot guarantee the protection of your Personal Data when transferred over the internet to us.
11. Links to Third-Party Websites
The Website may offer links to third-party websites and/or applications. The Company does not control these websites and applications, nor their collection and/or processing of your Personal Data, and we are not responsible for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.
Whenever you access such third-party websites and/or applications, we recommend that you carefully review their privacy policies before using these websites and/or applications and before disclosing any of your Personal Data.
13. Your Rights Regarding Your Personal Data
Generally, you have the right to request that we confirm whether Personal Data about you is being collected by us, to review such data, to rectify the content if necessary, and to erase the Personal Data no longer required by us. You may also restrict your consent to certain processing of your Personal Information.
If you are an EEA resident, please read this section below:
You are entitled to the following rights concerning your Personal Data. To exercise these rights, you may send a request to exercise your rights to the following email address:
Right of Access
You have the right to receive confirmation from the Company as to whether or not your Personal Data is being processed, and if so, access to the Personal Data and the followinginformation: (1) the objectives of the processing; (2) the types of Personal Data involved; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, especially recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if feasible, the expected duration for which the Personal Data will be stored, or, if not feasible, the criteria used to determine that duration; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information regarding its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.
The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any additional copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic format.
The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request impacts the rights and freedoms of others, the Company may not fulfill your request or may do so in a limited manner.
Right to rectification
You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.
Right to erasure
The following grounds apply: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular 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) thePersonal Data has been unlawfully processed; or (f) the Personal Data about you needs to be erased to comply with a legal obligation under European Union or Member State law to which the Company is subject.
This right is not applicable to the extent that processing is necessary (a) for compliance with a legal obligation that requires processing under European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.
Right to Restriction of Processing
You have the right to request that the Company restricts the processing of your Personal Data if one of the following applies: (a) the accuracy of the Personal Data is contested by you, allowing the Company time to verify the accuracy of the Personal Data; (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; (c) the Company no longer needs your Personal Data for processing, but you require it for the establishment, exercise, or defense of legal claims; (d) if the processing of your Personal Data is necessary for the purpose of the legitimate interests pursued by the Company or a third party, unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
If the processing of your Personal Data has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State.
Right to Data Portability
You possess the right to obtain your Personal Data, which you've supplied to the Company, in a structured, widely used, and machine-readable format. You also have the right to transfer that data to another entity if the processing is based on your consent or a contract you're part of, and if the processing is automated.
When exercising your right to data portability, you can request that your Personal Data be transferred directly from the Company to another entity, provided it is technically feasible. This right does not impact your or the Company's rights regarding data deletion. Furthermore, exercising this right must not adversely affect the rights and freedoms of others.
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 of any processing carried out prior to your withdrawal.
Right to Object
You have the right to object to the processing of your Personal Data at any time, particularly if it pertains to your specific circumstances and the processing is justified by the legitimate interests of the Company or a third party. This includes any profiling based on these interests. Upon your objection, we will cease processing your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Additionally, you have the right to 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 lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
Your rights concerning your Personal Data, as outlined in this section 13, may be restricted by European Union or Member State law to which the Company is subject.
We will provide you with the information requested according to your rights outlined in this section 13 without undue delay and, in any event, within one month of receiving the request. This period may be extended by two further 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 outlined in this section 13 shall be provided free of charge unless otherwise stated in this section 13. Where requests are manifestlyunfounded or excessive, particularly due to their repetitive nature, we may either (a) impose a reasonable fee, considering the administrative expenses of providing the information or communication or executing the requested action; or (b) deny the request.
The Company may ask you to provide additional details necessary to verify your identity in order to process your request in accordance with your rights outlined in this section 13, if we have reasonable doubts about the identity of the individual making the request.
12. Changes To This Policy
We may periodically update the terms of this Policy. Whenever we make changes to this Policy, we will inform you by publishing the revised Policy on the Website. Additionally, when we make significant changes, we will endeavor to notify you through communication channels we deem reasonably appropriate to ensure you are aware of such changes, and by posting a notice about these changes on the Website. Unless specified otherwise, all changes will become effective upon the publication of the updated Policy on our Website.