Privacy Policy

We are committed to being transparent about how we collect and process your personal information:

We want you to be informed about how your Personal Data is used and processed. To support this, we use various methods to provide you with relevant information about Personal Data use.
Where specific details are required, we will provide them at the appropriate time.
We welcome any questions and will clarify any limitations imposed by law. You can reach us by email at the address below: info@dawnvermovale.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for a range of purposes: to provide the website and connect you with third-party trading platforms (the "Services"), to improve the site, protect our rights and interests, maintain and deliver the Services, meet regulatory and legal obligations, and carry out administrative and business activities that support the use of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise meaningful rights over your Personal Data:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or have it transferred to you or a third party. We will accommodate your request.

Protect Your Personal Data

While no system can guarantee absolute security of your personal data, we are committed to employing a range of methods and measures to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the personal data the Company collects about natural persons, and how it processes, shares, and secures that data.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for users aged 18 and over. We do not knowingly collect personal data from, or permit access to our services by, anyone under the age of 18. If we become aware that personal data has been collected from 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. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our services or channels, or when we receive your information from third-party partners.

You are not required to provide personal information to the company. However, choosing not to do so may affect our ability to deliver our Services or grant you access to the website.

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering the Services or from granting you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information such as your online activity log, traffic data (including IP address, date and time of access), language preference, software crash logs, 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 with a third-party online trading platform through us.
Personal information provided 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 We process your personal data only where we have a valid legal basis to do so. The specific basis depends on the nature of the processing activity and our relationship with you. We process personal data on the following grounds: — Where processing is necessary to perform a contract with you, or to take steps at your request before entering into a contract. — Where processing is necessary to comply with a legal obligation to which we are subject. — Where processing is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms. — Where you have given your consent to the processing of your personal data for one or more specific purposes. Where we rely on consent as the legal basis, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Where providing personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, failure to provide the requested data may prevent us from delivering our Services or granting you access to the website. We do not process personal data for purposes incompatible with those for which it was originally collected, unless required or permitted by applicable law.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: Where we engage third-party service providers to perform services on our behalf, we require them to process your personal data only for the purposes for which it was shared and to maintain appropriate safeguards. We may disclose your personal data to third parties where required by law, regulation, or lawful authority, or where necessary to protect the rights, property, or safety of our company, our users, or others. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. Where this occurs, we will take reasonable steps to ensure your data remains protected in accordance with this policy. We do not sell your personal data to third parties for their own marketing purposes. Where personal data is transferred to third parties located outside your jurisdiction, we take appropriate measures to ensure that such transfers are carried out in compliance with applicable data protection requirements and that your data remains adequately protected. By using our services, you acknowledge that your personal data may be transferred to and processed by third parties as described in this section.

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. You may also request that we transmit specific Personal Data to third-party trading platforms of your choosing. In such cases, we will share the Personal Data you have provided to us directly with those platforms. Your Personal Data will then be subject to their respective privacy policies and may be shared with more than one trading platform. We may share Personal Data with affiliated entities or business partners where this 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 also share your Personal Data with prospective investors, acquirers, or lenders — whether in relation to the Company or any entity within its group — in connection with a potential or completed transaction, including the transfer or sale of assets, or any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any group entity.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. Some of these services may collect and process your personal data independently, in accordance with their own privacy policies. By using our website, you acknowledge that third-party providers may set cookies on your device and access data in connection with their services. Where third-party tools are integrated — such as analytics, advertising, or social media plugins — those providers operate as independent data controllers. We recommend reviewing their respective privacy policies to understand how your data is handled. You can manage or withdraw your consent to non-essential cookies at any time through your browser settings or our cookie preference centre. Disabling certain cookies may affect the functionality of some features on our website.

We may work with third-party service providers, including advertising networks and analytics companies. These providers may also use cookies or similar technologies on our website.
Cookies are small text files placed on your device when you visit the website. They are used to gather information about your browsing habits and preferences, improve your experience, remember your settings, and tailor the products and services presented to you. Cookies are also used for statistical and analytical 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 based on their purpose.

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of 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 where permitted by applicable law, regulation, or order.
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 regularly review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Information to a Third-Party Country or International Organisation Where we transfer your personal information to a third-party country or international organisation, we will ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection requirements. Such transfers will only occur where permitted by law and where adequate levels of protection are maintained.

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organisational measures to safeguard it against unauthorised access, loss, destruction, or alteration. While we implement appropriate security controls, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continuously review and update our measures to address emerging risks. You are responsible for keeping your account credentials confidential. Do not share your password with anyone. If you believe your account has been compromised, notify us immediately. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Once your data is no longer needed, we dispose of it securely. In the event of a data breach that affects your rights or interests, we will notify you and any relevant authorities as required, without undue delay.

We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards 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 required by legal or regulatory obligations beyond our control, we may be required to disclose your Personal Data to third parties, including public authorities. We cannot control the security measures applied to your Personal Data by such third parties.
Transmission of Personal Data over the internet is inherently not fully secure. We cannot guarantee the security of Personal Data you transmit to us online.

11. Links to Third-Party Websites

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

12. Modifications to This Policy We may update this Privacy Policy from time to time. When we do, we will revise the date at the top of the policy. If the changes are material, we will notify you by email or through a prominent notice on our website prior to the changes taking effect. We encourage you to review this policy periodically to stay informed about how we collect, use, and protect your personal data. Your continued use of our services after any changes constitutes your acceptance of the updated policy.

Before visiting any third-party website or app, read their privacy policy carefully. Only provide your personal data once you are satisfied with how it will be handled.

13. Your rights with respect to your personal information You have the following rights regarding your personal information: Right of access — You may request confirmation of whether we process your personal information and, if so, obtain a copy of that information along with details of how it is used. Right to rectification — You may request correction of any inaccurate or incomplete personal information we hold about you. Right to erasure — In certain circumstances, you may request that we delete your personal information. Right to restrict processing — You may request that we limit how we use your personal information in certain situations. Right to data portability — Where technically feasible, you may request that we transfer your personal information to you or to another organisation in a structured, machine-readable format. Right to object — You may object to the processing of your personal information where we rely on legitimate interests as our legal basis, or where we use it for direct marketing purposes. Right to withdraw consent — Where our processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before the withdrawal. Right to lodge a complaint — You have the right to lodge a complaint with the relevant data protection authority if you believe we have not handled your personal information in accordance with applicable law. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within the timeframes required by applicable law.

You have the right to request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also request that we restrict the types or scope 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 whether your Personal Data is being processed. If it is, you may request access to that data.
The Company will provide an electronic copy of your Personal Data currently being processed. A reasonable fee may be charged for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not infringe on the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response.
Right to rectification
The Company will correct inaccurate Personal Data upon request. You may also request that incomplete Personal Data be completed, taking into account the purposes for which it is processed.
Right to erasure
This right applies where: (a) the Personal Data is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party, and those interests do not override yours; (e) the Personal Data has been unlawfully processed; or (f) the 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 have concerns about 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, for the establishment, exercise, or defence of legal claims, for the protection of the rights of another person, or where there is a significant 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 your Personal Data in a structured, commonly used format.
You may request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure, and it must not infringe on the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. If the Company cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or that relate to the establishment, exercise, or defence of legal claims, processing will cease.
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to the withdrawal.
You have the right to lodge a complaint with the relevant supervisory authority.
You may 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 certain circumstances.
We will respond to requests made under section 13 within one month of receipt. Where necessary, this period may be extended by up to two months depending on the complexity or volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Unless otherwise limited under section 13, information provided in response to your rights will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly if repetitive, the Company may charge a reasonable administrative fee or decline to act on the request.
Where we have reasonable doubt about the identity of the person submitting a request, the Company may request additional information to confirm identity before proceeding.