Privacy Policy and Cookie Policy

LAST UPDATED: [MARCH 04, 2022]

Background:

Baremetals Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Platform and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Mobile App (“App” or “Platform). Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Platform. If you do not accept and agree with this Privacy Policy, you must stop using Our Platform immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

2. Data Protection Officer

Our data protection officer is [Daniel Asante] who can be contacted at contact@baremetals.io..

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Platform. It does not extend to any Platforms that are linked to from Our Platform (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other Platforms and We advise you to check the privacy policies of any such Platforms before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Platform, we may collect some or all the following data:

• Name;
• Date of Birth
• Gender
• Business/Company name
• Job Title
• Profession
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences and interests;
• financial information such as credit / debit card numbers;
• IP address (automatically collected);
• operating system (automatically collected);
• a list of URLs starting with a referring Platform, your activity on Our Platform, and the Platform you exit to (automatically collected);

5 How Do We Use Your Data?

• All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
• We use your data to provide the best possible services to you. This includes:
• Providing and managing your access to Our Platform;
• Personalising and tailoring your experience on Our Platform;
• Supplying Our services to you;
• Personalising and tailoring Our services for you;
• Responding to communications from you;
• In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
• With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by contact@baremetals.io with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 2015,ad 2021.
• Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary to protect the vital interests of you or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

• We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
• Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
• Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Platform.
• Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do We Share Your Data?

• We do not share your data with any third Party.
• In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
• In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

9. How Can You Control Your Data?

• When you submit information via Our Platform, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

• You may access certain areas of Our Platform without providing any data at all. However, to use all features and functions available on Our Platform you may be required to submit or allow for the collection of certain data.
• You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at contact@baremetals.io or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

• Our Platform may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Platform and to provide and improve Our services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is always protected and respected.
• By using Our Platform, you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by Platforms, services, and/or parties other than Us.
• All Cookies used by and on Our Platform are used in accordance with current English and EU Cookie Law.
• Before Cookies are placed on your computer or device, you will be shown a pop-up, message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Platform may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
• Our Platform uses analytics services provided by Google Analytics. Platform analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Platform. This, in turn, enables Us to improve Our Platform and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Platform, it does enable Us to continually improve Our Platform, making it a better and more useful experience for you.
• The analytics service(s) used by Our Platform use(s) Cookies to gather the required information.
• You can choose to enable or disable Cookies in the App. However, you may lose some of the functionalities of the App if you choose to do so.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Platform more quickly and efficiently including, but not limited to, login and personalisation settings.

13. Summary of Your Rights under GDPR

• Under the GDPR, you have:
• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Platform or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Automated Decision-Making and Profiling

• 14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
• 14.2 The right described in section 14.1 does not apply in the following circumstances:

• The decision is necessary for the entry into, or performance of, a contract between the You and Us;
• The decision is authorised by law; or
• You have given you explicit consent.

• 14.3 Where We use your personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;
• Appropriate mathematical or statistical procedures will be used;
• Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15. Contacting Us

If you have any questions about Our Platform or this Privacy Policy, please contact Us by email at contact@baremetals.io, or by post at the above stated address. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

16. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Platform and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Platform following the alterations. We recommend that you check this page regularly to keep up-to-date.