Privacy Policy

At Cliffs Fundmere, safeguarding your personal information is a cornerstone of our operations. This document details the types of data we gather when you interact with our digital trading platform, the explicit reasons behind this collection, and the extensive control you retain over your own information. We are committed to transparency in our data handling practices.

Interpretation and Definitions

To ensure absolute clarity throughout this document, certain capitalized terms carry the specific meanings outlined below. These definitions hold true whether the terms appear in singular or plural form.

• Account refers to the unique, secure profile you establish to access specific features of our Service.
• Affiliate denotes any entity that has a controlling interest in, is controlled by, or is under common control with Cliffs Fundmere. Here, 'control' signifies the ownership of 50% or more of the shares or other securities that have voting rights for the election of directors.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) identifies us, Cliffs Fundmere, the entity responsible for your data under this policy. For the purpose of the GDPR, we are the Data Controller. Our operational base is in the Republic of Ireland.
• Cookies are small text files placed on your computer or mobile device by our Website. They store details about your browsing history and serve various functions to improve your experience.
• Country specifically refers to the Republic of Ireland, our company's jurisdiction.
• Device encompasses any tool capable of accessing our Service, such as a desktop computer, a mobile phone, or a digital tablet.
• Personal Data signifies any piece of information that can be used, either on its own or in combination with other data, to identify a living individual.
• Service designates the full range of digital trading functionalities and content offered through our Website, accessible at https://cliffsfundmere.org.
• Service Provider means any third-party individual or company we engage to help deliver our Service. This includes entities that perform data analysis, host our infrastructure, or provide support functions on our behalf.
• Usage Data is data that is generated automatically, either by your interaction with the Service or from the Service's technical infrastructure itself (for instance, the duration of a page visit).
• website points to the Cliffs Fundmere online portal, located at https://cliffsfundmere.org.
• You indicates you, the individual person accessing or utilizing our Service, or the legal entity on whose behalf such an individual is accessing the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While engaging with our platform, particularly during account setup and for regulatory compliance, we might request specific personally identifiable information to contact or identify you. The scope of this information can include, but is not limited to:

• Email address
• First and last name
• Phone number
• Financial account information and identity verification documents required for Know Your Customer (KYC) compliance.
• Address, State, Province, ZIP/Postal code, City

Usage Data

Our systems automatically gather Usage Data as you navigate our Service. This type of information is generally non-personal but may become so if linked with other identifiers. Usage Data can include details such as your Device's Internet Protocol (IP) address, your browser type and version, the specific pages of our Service that you explore, the time and date of your visit, the amount of time spent on those pages, and other diagnostic data.

Tracking Technologies and Cookies

To enhance functionality, secure your sessions, and analyze traffic on our Website, we employ Cookies and analogous tracking technologies. These tools help us distinguish you from other users and refine your experience. We categorize the cookies we use as follows:

• Necessary / Essential Cookies: These are non-negotiable for the core operation of our Service. They enable essential functions like secure logins and transactional integrity and cannot be disabled in our systems as the Service would not function without them.
• Cookies Policy / Notice Acceptance Cookies: These simply record whether you have acknowledged and agreed to the use of cookies on our platform, preventing the notice from appearing on every visit.
• Functionality Cookies: These cookies allow us to remember choices you've made previously, such as your preferred language or login details. Their purpose is to provide a more personalized and streamlined interaction, saving you from re-entering your preferences each time you use the Service.

Use of Your Personal Data

Cliffs Fundmere processes your Personal Data for several distinct and legitimate purposes:

• For the provision and maintenance of our Service, which includes ongoing monitoring of its usage and performance.
• To administrate your user Account, including your registration and granting you access to different functionalities available to registered users.
• To execute and manage our contractual obligations, specifically concerning the development, compliance, and fulfillment of the purchase contract for products or services you have acquired through our platform.
• To communicate with you effectively, which may be via email, telephone calls, or other electronic messaging formats, regarding updates, security alerts, or informational notices related to your account or our services.
• To share information about new offerings or events that align with your interests, based on your previous activity, provided you have not opted out of receiving such communications.
• To efficiently process and respond to any requests or inquiries you direct to our support teams.
• In the context of evaluating or executing a mergerdivestiture, or other sale of some or all of our assets, where your Personal Data may be among the assets transferred.
• For ancillary internal purposes like data analysis, identifying emerging usage trends, and gauging the effectiveness of our promotional campaigns to improve our overall Service and user experience.

Sharing Your Personal Data

Your Personal Data is shared only under specific, controlled circumstances where there is a legitimate basis for doing so:

• With Service Providers: We may grant access to your Personal Data to trusted Service Providers who perform technical or operational functions for us (like payment processing or data analytics). They are contractually bound to maintain confidentiality and use the data solely for the purposes we define.
• For business transfers: If Cliffs Fundmere undergoes a merger, acquisition, or asset sale, your Personal Data may be transferred to the new entity. We will provide notice before this occurs and your data becomes subject to a different Privacy Policy.
• With our Affiliates: We might share information with our affiliated companies, with the strict requirement that they will adhere to the standards set out in this Privacy Policy.
• With business partners: On occasion, we may share certain data with our business partners to offer you specific co-branded products or promotions that may be of interest to you.
• With your explicit consent: Beyond these scenarios, we will only disclose your information to any other third party after receiving your explicit and unambiguous consent to do so.

Retention of Your Personal Data

Cliffs Fundmere will hold onto your Personal Data only for the duration necessary to fulfill the purposes outlined in this policy. We will retain and use your data to the extent required to meet our legal obligations (for instance, to comply with anti-money laundering regulations in Ireland which may require us to keep transaction records for a specific period), to resolve disputes, and to enforce our legal agreements and policies. Usage Data is generally kept for a shorter period, except when it is used to strengthen security or improve the functionality of our Service.

Transfer of Your Personal Data

The processing of your data occurs at our operational offices in Ireland and potentially in other locations where our Service Providers are based. This might involve transferring your information to — and maintaining it on — computer systems in a jurisdiction with different data protection laws than your own. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Cliffs Fundmere commits to ensuring any such transfer is conducted with robust safeguards, confirming your data is treated with the same level of security detailed here, and will only proceed if adequate protective measures are verified and in place.

Delete Your Personal Data

You possess the fundamental right to request the correction or deletion of the Personal Data we hold about you. You can update or remove certain information directly within your account settings interface. For any data you cannot alter yourself, or to request a full and permanent deletion of your account and associated information, please contact us directly. We will assist you in this process. Please be aware that we may be required by law to retain certain information, preventing its immediate deletion. In such cases, we will inform you of the legal basis for this retention.

Disclosure of Your Personal Data

Business Transactions

Should Cliffs Fundmere be involved in a significant corporate transaction such as a merger, acquisition, or the sale of assets, your Personal Data may be disclosed or transferred as part of that process to the involved parties under confidentiality agreements.

Law Enforcement

Under specific and legally binding circumstances, we may be compelled to disclose your Personal Data if requested by public authorities, such as a court or government agency, through a valid legal instrument like a subpoena or court order.

Other Legal Requirements

We may find it necessary to disclose your Personal Data if we have a good faith belief that the action is imperative for one of the following reasons:

• To comply with a pressing legal mandate.
• To protect and defend the rights or property of Cliffs Fundmere.
• To prevent or investigate potential wrongdoing in connection with the Service.
• To safeguard the personal safety of our users or the public.
• To protect ourselves against legal liability.

Security of Your Personal Data

The security of your Personal Data is a top priority for us. We employ a range of commercially acceptable means, including data encryption, access controls, and secure architecture, to protect it. However, it is crucial to acknowledge that no method of transmission over the Internet or method of electronic storage is 100% infallible. While we strive to use the strongest protections available, we cannot guarantee its absolute, unbreakable security.

Children's Privacy

Our Service is not designed for or intentionally targeted at individuals under the age of 13. We do not knowingly collect personally identifiable information from anyone in this age group. If you are a parent or guardian and become aware that your child has provided us with Personal Data without your consent, please contact us immediately. Upon verification, we will take prompt steps to remove that information from our servers.

Links to Other Websites

Our Service may contain hyperlinks to external websites that are not operated by Cliffs Fundmere. If you click on a third-party link, you will be directed to that site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policy of every site you visit to understand how they will handle your information.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy on this page and updating the "Last updated" date at the top. We encourage you to review this page periodically to stay informed about how we are protecting your information.

Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please do not hesitate to reach out to our support team.

• By email: [email protected]