Privacy Policy

1. The Scope

1.1 This policy describes the types of personal data the Company collects about individuals, and how it processes, shares with third parties, and secures that data.

This Policy covers information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified through a combination of additional information we hold or can reasonably access.

1.3 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we permit them to use our services. If we become aware that such information has been collected, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our services, channels, or website, we collect personal data. In certain instances, we may also request personal data directly from you.

2.2 We also collect your personal data by analysing how our Services and service channels are used, or by receiving your information from third-party partners.

3. No Requirement to Disclose Personal Information

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

4. What Personal Data We Collect

The information collected is not personally identifiable 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 connecting with a third-party online trading platform through us.

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

5. Legal Basis and Reasons for Processing of Personal Data

Your personal data is processed by the company for the purposes described in this section, in accordance with the applicable legal basis.

For more details on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following sets out the reasons and legal grounds on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share personal data with third-party service providers, including hosting and storage providers, IP address data handlers, and user experience analytics services.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data you have given us directly to those platforms. Your Personal Data may be shared with one or more third-party trading platforms, and its use will be governed by their respective privacy policies.

6.3 The Company may share Personal Data with related entities or business partners to enhance and improve the products and services provided to its customers.

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

We may share your Personal Data with potential investors, buyers, or lenders to the Company or any other group company in connection with a transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party services — such as advertisers and analytics providers — that operate on our website. These third parties may also use cookies or similar tracking technologies.

7.2 Cookies are small text files placed on your device when you visit the website. They collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and personalise the products and services most relevant to you. Cookies are also used for statistics and analytics purposes.

Some cookies we use are session cookies — these are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after the browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help restore your access on subsequent visits.

7.5 Please note that if this occurs, some or all of the Website's features and functions may not operate as expected.

Online Tracking Notice: This service does not currently recognise do-not-track signals.

8. Retention of Personal Data

We will 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, regulations, or orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or shared with international organisations. The Company takes all necessary steps to protect your personal data and ensure you retain the ability to exercise your rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, contact us at: support@tarrowmintprime.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your Personal Data will be kept secure without error at all times. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including disclosures caused by transmission errors, unauthorised third-party access, or other circumstances beyond our reasonable control.

10.3 In certain circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect your Personal Data.

10.4 Transmitting personal data over the internet carries inherent security risks. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how these sites or applications collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

11.2 When visiting any third-party websites or apps, read their privacy policies before deciding to access or use them. Exercise caution when sharing any Personal Data with such third parties.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.

12.2 When we make significant changes to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless otherwise specified, any amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You have the right to request verification of the accuracy of your Personal Data being collected, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.

If you are a resident of the EEA, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, please contact us at the email address below.

13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. This right to access must not infringe on the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You have the right to request that incomplete Personal Data relating to you be rectified, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request the erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer necessary 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 specific situation, to the processing of Personal Data about you where that processing 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 applicable to the company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where such a restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or where there is a substantial public interest ground recognised within the European Union or a Member State.

13.7 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 also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to challenge You have the right to 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. This right extends beyond profiling based solely on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal rights, we may continue the processing despite your objection. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.

13.9 Right to Withdraw Consent You may withdraw your consent for Us to process your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, you may submit a complaint to a supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that applicable laws of the European Union and its member states may limit the rights described in this section 13.

We will provide the information requested under your rights in Section 13 of this agreement within one month of receiving your request. If the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of fulfilling the request or notifying you of the action taken. We may also decline to act on such requests.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that individual to provide suitable means of verification.