Privacy Policy

1. The Scope

1.1 This policy sets out the types of personal data the Company collects about individuals, and how that data is processed, shared with third parties, and kept secure.

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

1.3 For the purposes of 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 knowingly permit them to use our services. Should we become aware that any such information has been collected, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services and channels, or visit our website, we collect personal data. We may also request personal data from you in certain circumstances.

2.2 In other cases, we 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 obliged to provide us with any personal data. However, in certain circumstances, withholding personal data may prevent us from providing the Services or prevent you from accessing the website.

4. What Personal Data We Collect

4.2 The information collected is not personal data 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: this 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 set out in this section, in accordance with the applicable legal basis.

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

5.4 Below is a list of 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 companies that provide services on our behalf, including hosting and storage providers, IP address information, and user experience analysis.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms. Your Personal Data on those platforms is governed by their respective privacy policies. Your Personal Data may be shared with more than one 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 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 also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other group company, in connection with a transaction involving the transfer or sale of 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 Third parties — such as advertisers and analytics providers — may operate on our website and may use cookies or similar technologies.

7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your preferences and browsing habits, maintain your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytical 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 the browser is closed. These are used to recognise you as a returning user and help you access the website more easily on subsequent visits.

7.5 Please note that disabling these settings may affect how some or all of the Website's functions and features perform.

Online Tracking Notice: This service does not currently respond to 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, regulation, or order.

8.2 We will share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue to share your data 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 to international organisations. The Company takes all necessary steps to protect your personal data and ensure that you retain the ability to exercise your rights and access effective legal remedies.

9.3 The Company can provide details of the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@zestgainory.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 entirely secure or free from error. We are not liable for any indirect, 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 reasonable control.

10.3 Where legal or other obligations beyond our control require us to share your Personal Data with third parties, such as public authorities, we may be obliged to do so. In such cases, we cannot control how those third parties handle or secure 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 transmit to us online.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These are not under the Company's supervision, and we are not responsible for how such sites or apps collect or process personal data. This Policy does not apply to actions taken through third-party sites or applications.

When visiting any third-party websites or apps, please read their privacy policies before deciding to access or use them. You should also consider carefully what personal data you share with them.

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 updated Policy on our website.

12.2 Where we make significant changes to this Policy, we will notify you through appropriate means 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

13.1 You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also restrict the types or scope of processing applied to your personal data.

If you are an EEA resident, please refer to this page for details on the rights available to you 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 being processed and may charge a reasonable fee for additional copies. Data will be made available electronically upon request. The right of access must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of a third party, the Company may refuse or limit its compliance with that request.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You may request that incomplete Personal Data relating to you be corrected, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request 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 to the processing of your Personal Data where that processing is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to comply with 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 ask the Company to restrict its processing. Where 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 there is a substantial 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 held by the Company in a structured 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 does not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of your Personal Data where it is based on legitimate interests pursued by the Company or a third party, including profiling based on those 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 claims, we may continue to do so. Concerning 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 withdraw 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 on the basis of your consent prior to its withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. This includes any 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. Please note that the laws of the European Union and its Member States may limit the rights described in this section 13 as they apply to your Personal Data.

We will respond to requests made under your rights in section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two additional months, depending on the complexity or volume of requests received. 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 providing the information or carrying out the requested action. We may also decline to act on such requests.

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