Privacy Policy

1. The Scope

Section 1.1 describes the types of personal data the Company collects from individuals, and how that data is processed, shared with third parties, and protected.

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 "Processing" refers to any activity involving the use or collection of Personal Data, including its organization, structuring, and storage.

Our services are intended for general audiences and are not available to anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we permit them to use our services. If we become aware that we hold information relating to a minor, 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 analyzing how our Services and service channels are used, or by receiving your information from our 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 the Services or granting you access to the website.

4. What Personal Data We Collect

The information collected is not personal and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when you connect 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, under the applicable legal basis for each purpose.

For more details on how we process your data to protect legitimate interests, contact us by email.

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

6. Transfer of Personal Data to Third Party

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 platforms.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will disclose the Personal Data you have provided to us to those platforms. Your Personal Data will then be governed by their respective privacy policies. Please note that your Personal Data may be shared with more than one third-party trading platform.

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 competent authorities.

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

7. Cookies and Services from Third Parties

We may use third-party services — such as advertisers and analytics providers — 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 habits to improve your experience, remember your settings, and tailor the products and services relevant 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 once you close your browser. Others are persistent cookies, which remain on your device after the browser is closed. These are used to recognize you as a returning user and allow you to resume access to the Website.

Please note that some or all Website features may not work as expected if this occurs.

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

8. Retention of Personal Data

We will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you agree, we will continue sharing your data for a further 12 months.

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

9. International Transfers

Your personal information may be transferred to other countries or shared with international organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the right to assert 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, email: support@novakapitune.com

10. Security of Personal Data

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

We cannot guarantee that the security of your Personal Data will be maintained without error. We are not liable for any incidental or consequential damages arising from the use or disclosure of Personal Data, including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.

In certain situations, we may be legally or otherwise required to share your Personal Data with third parties, including public authorities. In such cases, we have no control over how those third parties protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These sites and applications 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 applications.

Before visiting any third-party website or app, read their privacy policy carefully. Be mindful of the personal data you share with them.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be reflected in the updated Policy posted 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 we collect, to have any inaccuracies corrected, and to request deletion of 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 regarding your Personal Data. To exercise any of these rights, send a written request to the email address below.

13.3 Access rights You have the right to verify that the Company is processing your Personal Data accurately and, if so, to access that data. The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. If you request the data in electronic format, it will be provided accordingly. The right to access Personal Data must not conflict with the rights and freedoms of others. Where fulfilling a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response.

13.4 Right to rectification We may correct inaccurate Personal Data held about you. You may also request that incomplete Personal Data be rectified, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request the erasure of your Personal Data under 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 specific to your situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to fulfill a legal obligation of 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 rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Once a restriction is in place, 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 significant public interest 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 from the Company to another controller, where technically feasible. Exercising this right 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 the processing of your Personal Data where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. If 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 defense of legal claims, we may continue to process your Personal Data despite your objection. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to Refuse Consent You may withdraw your consent for Us processing Personal Data about you at any time. This does not affect the lawfulness of any processing carried out prior to your withdrawal. 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. Applicable European Union and member state laws may limit your rights regarding Personal Data as set out in this section 13.

We will fulfill requests made under Section 13 of this agreement within one month of receipt. Depending on the complexity or volume of requests, this period may be extended by up to two additional months. If an extension is required, we will notify you within one month of receiving your request and provide the reasons for the delay.

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 repetitive — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

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