Política de Privacidad

1. El Alcance

This policy describes the personal data the Company collects about individuals, how that data is processed and shared with third parties, how it is protected, and other related matters.

1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly through a combination of additional information we hold or have access to.

1.3 For the purposes of this Policy, "processing" refers to any operation involving the use or collection of Personal Data, including its management, structuring, and storage.

Our services are intended for a general audience and are not designed for individuals under 18 years of age. We do not seek or knowingly collect information from minors. If we become aware that we hold data belonging to a minor, we will delete it promptly.

2. Qué Datos Personales Tenemos Sobre Usted

When you access our services, channels, or website, we collect your Personal Data. In certain circumstances, we may also request additional Personal Data from you.

In some cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving your information from third-party partners.

3. Sin Obligación de Divulgar Información Personal

You are not required to provide us with any personal data. However, withholding certain personal data may prevent you from accessing the Services or limit your ability to use the website.

4. Qué Datos Personales Recopilamos

The information we collect is non-personal and cannot be used to identify you.

4.3 Personal data you provide to us: any personal data you voluntarily share when connecting to a third-party online trading platform through us.

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

5. Legal Basis and Grounds for Processing Personal Data We process your personal data only when we have a valid legal basis to do so. The specific grounds depend on the nature of the data and the purpose for which it is collected. The following legal bases may apply: Contractual necessity: We process personal data when it is necessary to fulfill a contract with you or to take steps at your request before entering into one. Legal obligation: We may process personal data to comply with applicable legal or regulatory requirements. Legitimate interests: Where permitted by law, we process personal data to pursue our legitimate business interests, provided those interests are not overridden by your rights and freedoms. Consent: In certain cases, we process personal data based on your explicit consent. Where consent is the legal basis, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal. Vital interests: We may process personal data where necessary to protect your vital interests or those of another person. Withholding personal data where it is required may prevent us from delivering our Services or granting you access to the website. Where this is the case, we will inform you at the time of collection.

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

5.3 Contact us by email for details on the processing required to safeguard legitimate interests.

5.4 Below is a list of the reasons and legal bases on which we may use the information you provide to us:

6. Transferencia de Datos Personales a Terceros

6.1 The Company may also share Personal Data with third-party service providers, including IP address hosting and storage providers, as well as platforms used to analyze user experience.

You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide those platforms with the Personal Data you have supplied to us. Your Personal Data will be subject to each platform's privacy policy. Your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with affiliated entities or business partners to improve and optimize the products and services offered to its clients.

6.4 To protect the rights or assets of third parties, the Company is authorized to disclose Personal Data to regulatory, local, or other official authorities.

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

7. Cookies y Servicios de Terceros

We may use third-party services, such as advertisers on our website or data analytics companies. These third parties may also use cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and personalize the products and services most relevant to you. Cookies are also used for statistical and analytical purposes.

Certain cookies used on this Website are session cookies. These are temporarily stored on your device and expire when you close your browser. Other cookies are persistent — they remain on your device after your browser is closed and are used to recognize you as a returning user, allowing the Website to restore your previous session.

7.5 Please note that if this occurs, some or all website features and functionality may not work as expected.

Online Tracking Notice: This service does not currently support Do Not Track signals.

8. Retención de Datos Personales

La Compañía conservará sus Datos Personales durante el tiempo necesario para cumplir con los fines del tratamiento descritos en esta Política, o por períodos más prolongados según lo permitan la ley, las regulaciones, las políticas y las órdenes aplicables.

Your information will be shared with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for an additional 12 months.

8.3 We periodically review the Personal Data we have retained to confirm it is no longer needed.

9. Transferencias Internacionales

Su información personal puede ser transferida a otros países, lo que incluye la transmisión de datos personales a terceros países u organizaciones internacionales. La Compañía adopta todas las medidas necesarias para proteger los Datos Personales que usted proporciona y garantizar que quienes los traten puedan ejercer sus derechos y acceder a recursos legales efectivos.

9.3 The Company can provide information about the security measures it uses to protect Personal Data transferred to third countries or international organizations. To request this information, email: support@cumbremaduranza.com

10. Seguridad de los Datos Personales

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

We cannot guarantee that your Personal Data will be kept free from errors at all times. We are not liable for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other cause beyond our control.

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

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to us online.

11. Hipervínculos a sitios web de terceros

Our website includes links to third-party sites and applications. These are not operated or supervised by the Company. We are not responsible for how those sites or applications collect or process personal data. This Policy does not apply to any actions taken through third-party sites or applications.

When accessing any third-party websites or applications, read their privacy policies before deciding to use them. Exercise caution when sharing any personal data with those platforms.

12. Modificaciones a Esta Política

This Policy may be updated at any time. Any changes will be reflected in the updated Policy published on our website.

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

12.3 Unless otherwise stated, any changes take effect upon publication of the revised Policy.

13. Sus Derechos

You have the right to request that we verify the accuracy of your Personal Data, correct any errors, and delete any Personal Data we no longer need. You may also restrict the scope of how your Personal Data is processed.

If you are an EEA resident, please refer to this page. These rights apply to the personal data you provide to us. To exercise your rights, send an email to the address listed below.

13.3 Right of Access You have the right to verify the accuracy of your Personal Data that the Company processes. Upon request, the Company will provide an electronic copy of your Personal Data currently being processed. A reasonable fee may apply for additional copies. If you request data in electronic format, it will be provided in that format. The right of access to Personal Data must not conflict with the rights and freedoms of third parties. If a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to Rectification The Company has the right to correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of the processing.

13.5 Right to Erasure The following grounds apply: (a) the personal data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and no legal basis for processing exists; (c) you object, at any time and on grounds specific to your situation, to the processing of personal data about you where that processing is based on legitimate interests pursued by us or by third parties; (e) the personal data has been processed unlawfully; 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 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 natural person, or where a significant public interest reason exists 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 on a contract to which you are a party, you have the right to access and review the Personal Data you have provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect any rights you hold under the right to erasure. The right to data transfer does not interfere with the rights or freedoms of third parties.

13.8 Right to Object You have the right at any time to object to any use of your Personal Data based on the legitimate interests pursued by the Company or a third party. This includes, but is not limited to, profiling based on those legitimate interests. Where we can establish compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests override those grounds, or that the processing affects the exercise, establishment, or defense of legal claims. With respect to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

13.9 Right to Withdraw Consent You may withdraw your consent to the processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that point. You also have the right to lodge a complaint with a supervisory authority established by an EU member state to protect individuals' fundamental rights in relation to the processing of Personal Data within the European Union. EU and member state law may limit your rights regarding your Personal Data as set out in this section 13.

13.10 We will provide the information requested under the rights set out in section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and volume of requests received. We will notify you of any extension, and the reasons for it, within one month of receiving your request.

13.11 Unless prohibited by the provisions of Article 13 of the law, information requested under your rights pursuant to that article will be provided free of charge. If a request is unjustified or excessive — particularly where it is repetitive — we may charge a reasonable fee to cover the administrative costs of providing the information or notifying you of the action taken. We may also elect not to act on the request.

If there is any doubt about the identity of the person who submitted a request, we may ask them to provide reasonable means of verification.