Privacy Policy

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

We want you to make informed decisions 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. If you have any questions or need clarification regarding any legally imposed limitations, we are happy to assist. You can reach us by email at the address below: info@zephyranlagmere.com

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

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

To exercise meaningful tools that protect your rights in relation to 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 transfer it to you or a third party. We will accommodate your request.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of personal data the Company collects about natural persons, and how that data is processed, shared with third parties, and secured.
This policy applies to information that relates to an identified or identifiable natural person. An identifiable person is one who 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 older. 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. We may request this directly from you, gather it by monitoring how our services and channels are used, or receive it from our third-party partners.

You are not required to provide personal information to the company. However, choosing not to do so may prevent us from delivering our Services or granting you access to the website.

Providing personal data is not mandatory. However, withholding it 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:

This includes information such as your online activity log, traffic data (including IP address, date of access, and time of access), language settings, software crash logs, browser type, and device details. This information 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

6. Transfer of Personal Data to 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 assist in operating our platform and delivering our services. These parties are contractually bound to process your personal data only as instructed and to maintain appropriate security standards. Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party. We will notify you of any such transfer and any resulting changes to this policy. Legal Obligations: We may disclose your personal data to regulatory authorities, law enforcement, or other third parties where required by law or where necessary to protect our legal rights. Third-Party Links: Our platform may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their respective privacy policies. International Transfers: Where your personal data is transferred outside South Africa, we take reasonable steps to ensure it receives an equivalent level of protection in accordance with applicable data protection requirements. We do not sell your personal data to third parties. Any sharing of personal data is limited to what is necessary for the purposes described in this policy.

We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers, as well as platforms that analyse user experience and IP address data.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be passed to those platforms and will be subject to their respective privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with related 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 potential investors, buyers, or lenders in connection with any proposed or completed transaction involving the Company or any entity within its group — including the transfer or sale of assets, or any merger, restructuring, consolidation, or bankruptcy.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. Some of these services are provided by external companies that may process your personal data independently, subject to their own privacy policies. Third-party services we use may include analytics tools, advertising networks, and social media integrations. These services may set their own cookies or collect data about your browsing activity on our website. You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of some features on our website. By continuing to use our website, you consent to the use of cookies and third-party services as described in this section. For more detail on how we use cookies, please refer to our Cookie Policy.

We may use 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 are used to gather information about your preferences and browsing habits, improve your experience, and personalise the products and services presented 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 session.

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. 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.
We share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data 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 personal information to a third-party country or international organisation, we take appropriate measures to ensure that such transfers are conducted in accordance with applicable data protection requirements. These measures are designed to protect your personal information and ensure it receives a level of protection consistent with that afforded under South African law. We will only transfer your personal information to a third party outside South Africa where we have a lawful basis for doing so, and where adequate safeguards are in place. You may request further information about the specific measures applicable to any such transfer by contacting us through the details provided in this policy.

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures are reviewed and updated regularly to reflect changes in technology and security best practices. Access to your personal data is restricted to employees, contractors, and third parties who have a legitimate business need to process it. All such parties are subject to confidentiality obligations and may only process personal data on our instructions. Where we have provided you with account credentials or a password, you are responsible for keeping these confidential. Do not share your credentials with anyone. While we take the protection of your personal data seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we maintain rigorous safeguards to minimise risk. If you suspect any unauthorised access to or misuse of your personal data, contact us immediately so that appropriate action can be taken.

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 intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, any disclosure 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 your Personal Data to third parties, including public authorities. In such circumstances, we have no control over the security measures applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of any Personal Data you transmit to us through the internet.

11. Links to Third-Party Websites

Our website contains links to third-party websites and applications. These 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 third-party sites or apps.
Before accessing or using any third-party website or application, we recommend reading their privacy policy carefully and considering what Personal Data you choose to share with them.

12. Modifications to this Policy We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, communicated to you directly. Your continued use of our services after any modifications constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of any updates.

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, subject to applicable law: The right to be informed — you have the right to know how your personal information is collected, used, and shared. The right of access — you may request a copy of the personal information we hold about you. The right to rectification — you may request that we correct any inaccurate or incomplete personal information. The right to erasure — in certain circumstances, you may request that we delete your personal information. The right to restrict processing — you may request that we limit how we use your personal information in certain situations. The right to data portability — where applicable, you may request that we transfer your personal information to you or a third party in a structured, commonly used format. The right to object — you may object to the processing of your personal information where we rely on legitimate interests as our legal basis. The right to withdraw consent — where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. The right not to be subject to automated decision-making — you have the right not to be subject to a decision based solely on automated processing where that decision produces legal or similarly significant effects. To exercise any of these rights, please contact us using the details provided in this policy. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing your request. If you are dissatisfied with how we have handled your personal information, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

You have the right to request that we verify the accuracy of Personal Data being processed about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also request restrictions on the scope or type of processing applied to your personal data.
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 your request by email to the address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. Where confirmed, 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 in electronic format upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may decline or limit its response.
Right to rectification
The Company is required to correct inaccurate Personal Data. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is being processed.
Right to erasure
This right applies where: (a) the 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 to processing based on legitimate interests pursued by us or a third party, and those interests do not override your own; (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 rights.
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, or to establish, exercise, or defend legal rights, to protect the rights of another individual, 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 to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure, and does not infringe on the rights or freedoms of others.
Right to object
You may object at any time 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 solely on those interests. Where we cannot demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, we will cease processing.
You have the right to object at any time to the processing of Personal Data concerning you for direct marketing purposes.
Right to withdraw consent
You may withdraw consent to our processing of your Personal Data at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.
You have the right to lodge a complaint with a 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.
We will respond to requests made under the rights set out in section 13 of this agreement 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.
Unless otherwise provided under section 13, information provided in response to a request will be supplied free of charge. Where requests are unfounded or excessive, in particular where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt as to the identity of the person submitting a request, we may request additional information to confirm that identity.