PRIVACY POLICY

1. Introduction
This Privacy Policy ("Policy") of Cloverum ("we", "us" or "our") is committed to maintaining the accuracy, confidentiality, preserving the privacy, and security of your personally identifiable information ("Personal Information") you provide to us while using https://my.cloverum.io ("Website"). As part of this commitment, this Policy governs our actions as they relate to the processing, collection, use, maintenance and disclosure of your Personal Information when you use the Website.
You should read the Policy carefully before starting to use the Website in any manner, which will help you understand how we process, collect, use, maintain, and disclose your Personal Information, as well as your privacy rights.
This document applies to two separate legal entities, working under brand name Cloverum:
Cloverum Finance (CY) Limited — incorporated under the laws of the Republic of Cyprus.
Cloverum Finance Limited— incorporated under the laws of Gibraltar.
The applicable part of this Policy depends on which legal entity you have a contractual relationship with:
Cloverum Finance (CY) Limited is subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the applicable data protection laws of Cyprus.
Cloverum Finance Limited is subject to the Gibraltar Data Protection Act 2004, which is based on the GDPR principles but applies within Gibraltar's legal framework.
By using our website and services, you acknowledge that your personal data will be processed by the relevant entity in accordance with this Policy and the applicable legislation. You can withdraw your consent at any time, in this case send a message to us on the following email [email protected].
By visiting the Website, you hereby consent to our Policy and agree to its terms. If you do not agree with any provisions of this Policy, you should immediately discontinue your access to the Website and stop using any services provided through the Website.
2. Contact details
If you have any questions related to this Policy, as well as processing, collection, use, maintenance and disclosure of your Personal Information, please contact us [email protected]. You may file a complaint if you believe your rights were infringed, contacting us by the same E-Mail. You may also complain to the relevant authority where your habitual residence, place of work, or place of the alleged infringement of your rights.
The relevant data protection authority in Cyprus is the Office of the Commissioner for Personal Data Protection. The address of the Office of the Commissioner for Personal Data Protection is: Iasonos 1, 1082 Nicosia, Cyprus.
Email: [email protected], website: https://www.dataprotection.gov.cy/
The relevant data protection authority in Gibraltar is the Gibraltar Regulatory Authority (GRA). Address: 2nd Floor, Eurotowers 4, 1 Europort Road, Gibraltar GX11 1AA.
Email: [email protected], website: https://www.gra.gi/
3. Information we collect
You submit your Personal Information directly to us through the registration process at the Website. To become a user of services provided through the Website you will need to create an account by registering on the Website and creating a username and password. Personal Information which may be provided by you and collected by us contains:
• First name, last name (copy of your ID document);
• ID information (name of the document, date of issue, date of expiry, number, issuing authority, country of issue);
• Date of birth;
• Place of birth;
• Nationality;
• Username;
• Password;
• Gender;
• Tax code;
• Email address;
• Phone number;
• Device fingerprint;
• Geolocation details;
• Residence or mailing address;
• Cryptocurrency address;
• Types of swapped virtual currencies;
• Copies of corporate documents, including your Corporate Certificates, Power of Attorney for representative;
• Registration information (company name, registered number, registered address, authorized persons);
• Annual income, yearly turnover;
• Ultimate beneficial owners data (first name, last name (copy of ID document), ID information (name of the document, date of issue, date of expiry, number, issuing authority, country of issue), date of birth, place of birth, nationality, gender, tax code);
• Information about politically exposed persons;
• Payment details (your payment instrument number (such as a credit card number), and the security code associated with your payment instrument);
• Transaction details (amount, currency, time of transaction, address of the sender of the transaction, address of the payee of the transaction etc.);
• Support team messages.
All Personal Information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Information.
We also track your information provided to us by your browser or when you use the Website, such as browser and device characteristics, IP address, time and date of the access, geolocation, history of your activity on the Website, operating system, language preferences, referring URLs, device name, location, and other information. This information is needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.
We may also collect limited data from public databases, marketing partners, and other outside sources. In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, affiliate programs, joint marketing partners, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles.
4. Cookies
We also collect information through cookies and similar technologies. A cookie is a small computer file or piece of information that may be stored in your computer's hard drive when you visit our Website. This means information that our Website's server transfers to your computer. This information can be used to track your session on our Website. We may use cookies to improve our Website's functionality. Cookies may also be used to customize our Website content for you as an individual.
Cookies are widely used, and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our Website.
5. How we use, process and share information
The Personal Information shall:
• be processed lawfully, fairly and transparently;
• be kept to the original purpose;
• be minimized (i.e. only the Personal Information that is necessary is collected);
• have the accuracy upheld;
• be removed if it is not necessary;
• be kept confidential and their integrity maintained.
In general, the Personal Information you provide to us is used to:
• facilitate your account creation and Login/Set up process on the Website;
• facilitate delivery of our services through the Website to you, improve, and administer our services;
• provide access to our Website, operate, and maintain our Website;
• improve, personalize, and expand our Website, provide technical support to you;
• understand and analyze how you use our Website;
• help us communicate with you, contact with you in response to your questions and inquiries, solicit feedback from you;
• security and fraud prevention;
• meet any applicable legal process or enforceable governmental request;
• enforce our terms, conditions and policies for business purposes;
• comply with legal and regulatory requirements, inform you about the offers.
We may share Personal Information with third parties if we have a good-faith belief that use, access, preservation or disclosure of the information is reasonably necessary.
Except as otherwise stated in this Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with our vendors, service providers, contractors, representatives or agents who are performing services for us or on our behalf, with our affiliates, with law enforcement or regulatory agencies, if required.
Legal basis for processing your Personal Information:
• you have given us the consent to the processing of your Personal Information for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary in order to protect your vital interests or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information.
We may also process your Personal Information for other purposes with your consent.
6. Your rights related to the Personal Information
You are entitled to the following rights:
1. The right to access.
   You have the right to request copies of your Personal Information, information about collection, processing, usage, and maintenance of your Personal Information. No fee is charged in this regard.
2. The right to erasure.
   You have the right to request that we erase your Personal Information if:
   • The Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   • You withdraw consent on which the processing is based;
   • You object to processing pursuant to GDPR or Gibraltar Data Protection Act 2004 and there are no overriding legitimate grounds for the processing;
   • The Personal Information has been unlawfully processed;
   • The Personal Information has to be erased for compliance with a legal obligation of us.
3. The right to restrict processing
   You have the right to request that we restrict the processing of your Personal Information. That means we temporarily stop processing your Personal Information as you requested as long as your requests meets one of the following:
   • You contest the accuracy of the Personal Information;
   • You object to unlawful processing and you prefer to restrict the processing rather than erasing your Personal Information;
   • We do not need the Personal Information for processing, but we need to keep the Personal Information pursuant to the establishment, exercise, or defence of a legal claim.
   If we temporarily stop processing your Personal Information, then we will inform you before lifting the restriction and resuming the processing.
4. The right to object to processing.
   You have the right to object to our processing of your Personal Information. It means that we shall no longer process the Personal Information unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims. You can object at any time when the objection relates to marketing.
5. The right to data portability.
   You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you. You have the right to receive your Personal Information which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those information to another controller.
   Other rights set out in this Policy.
   You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to you, you can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. You can also indicate that you do not wish to receive marketing communications from us.
7. Enforcement of your privacy rights
If you would like to exercise any of your privacy rights, please contact us in writing by email [email protected] and submit your identifying details (first and last name), contact details (email, phone number), ID document, and detailed description of the information related to your Personal Information you look forward to enforce. If you make a request to us, we have one month to respond to you.
8. Protection of your Personal Information
We have implemented appropriate and reasonable technical and organizational security measures designed to protect your Personal Information from unauthorized access. Your account is protected by your account password, and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use.
However, despite our safeguards and efforts to secure your information, we cannot guarantee to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, disclose, or alter your Personal Information.
Although we will do our best to protect your Personal Information, transmission of Personal Information to and from us is at your risk. By using the Website, you acknowledge that you understand and agree to assume these risks. You should only access the Website within a secure environment.
9. How long do we keep your Personal Information
We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this Policy will require us keeping your personal information for longer than 2 years.
Your Personal Information to be deleted once the purpose of its collection specified in this Policy, has been fulfilled.
10. Other Websites
Our Website may contain links to other third party websites that are not governed by this Policy. Our Policy will no longer apply once you leave our Website. Additionally, we are not responsible for the privacy policies implemented by third party websites. Therefore, we suggest that you examine the privacy statements of those websites to learn how your information may be collected, used, shared, and disclosed.
11. Changes to our Policy
We reserve the right to change this Policy at any time. We will notify you of significant changes to our Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Website. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Website and this privacy page for updates.