Privacy Policy

Our Beginning

We – referred to as "We" or "Our" – are committed to protecting your personal information and your privacy.

This Privacy Policy is designed to explain how we collect, store, process, and use the information you provide in connection with the Borealmere website (hereinafter the "Site").

We commit to following these principles:

Transparency in the collection and processing of your personal data:

We ensure that you are always well-informed so that you can make conscious choices about how your data is used on the site or when interacting with third-party platforms. We use various methods to provide you with accurate and timely information regarding the processing of your data.

If we need to provide you with specific information, we ensure it is delivered at the right time and place.

We are also available to answer questions or provide clarifications, within the bounds of applicable law. You can reach us by email: [email protected]

Processing of personal data only for the purposes stated in this policy:

We may process your information to make the site available, connect you with third-party trading platforms (the "Services"), improve user experience, develop the platform, protect our rights, carry out administrative processes, and fulfill legal requirements.

We also process information to better understand your needs and preferences.

Resources to safeguard your rights:

We allocate significant resources to ensure that you can exercise your rights as a data subject. You can request access, correction, deletion, or restriction of your information, or request to have it transferred, at any time. We will respond in accordance with applicable law.

Protection of your personal data:

While we cannot guarantee absolute security, we use modern security methods and measures to protect your information and will continue to improve them.

Our Complete Privacy Policy

1. Scope

This policy describes the types of data we collect, how we process them, share them with third parties, and the security measures we apply.

"Personal Data" means any information that can be linked to an identified or identifiable person. "Processing" means any operation such as collection, storage, use, sharing, modification, or deletion.

Our services are intended for a general audience and are not directed at individuals under 18 years of age. We do not knowingly collect information from minors. If we discover that such information has been recorded, we will delete it promptly.

2. When do we collect information?

We collect data when you use our services, visit the site, or interact with our channels. Some information you provide directly, while others are collected automatically through analysis of your activity or via third-party partners.

3. No obligation to provide data – but consequences

You are not required to provide us with information. However, without certain data, we cannot offer you all our services or grant you full access to the site.

4. What types of information do we collect?

This may include activity logs, IP addresses, timestamps, language, browser type, device information, and error logs. Some of this may not directly identify you and is therefore not considered personal data.

Information you provide to us directly: name, phone number, email address when you contact us or use the platform.

5. Purposes of processing and legal basis

Borealmere processes data only when we have a legal basis, such as to provide services, improve the experience, protect your data, or comply with legal obligations.

• You have given consent for the processing of your personal data for specific purposes. This applies when you consciously share information via the site so that we can forward it to a third-party trading platform.
• Processing is necessary to pursue legitimate interests pursued by Borealmere or a third party. For example, this may include improving our services or handling legal claims.
• Processing is necessary to comply with a legal obligation to which Borealmere is subject.

If you would like further explanation of how processing your personal data serves the legitimate interests of Borealmere or a third party, you may contact us by email at any time.

Below is an overview of why we may process your data, along with the legal bases:

6. Transfer of personal data to third parties

Borealmere may share your information with third-party providers that assist with storage, hosting, IP information, user experience analytics, research, and other technical or diagnostic services.

If you request it, we may also transfer certain information to third-party trading platforms. In such cases, these parties will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.

Borealmere may also share information with affiliated companies and business partners that help improve the quality of our services.

We may disclose information to public authorities if necessary to protect our or third parties' interests, rights, or assets, including in connection with legal proceedings.

Information may also be shared with potential buyers, investors, or lenders in connection with a merger, acquisition, reorganization, or bankruptcy proceedings.

7. Cookies and third-party services

We use certain third-party services, such as analytics and advertising providers. These may use cookies or similar technology, governed by their own policies.

A cookie is a small text file stored on your device when you visit the site. It may collect information about usage patterns, preferences, and technical data, and is used to improve your experience, remember settings, and deliver more relevant content.

We may use both session cookies (which are deleted when the browser is closed) and persistent cookies (which remain on your device until they expire or are manually deleted).

Types of cookies:

Blocking and deleting cookies

You can change your browser settings to block or delete cookies. Links to instructions for the most common browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some features of the site may stop working if you block cookies.

NOTICE REGARDING ONLINE TRACKING

This service currently does not support "Do Not Track" signals.

8. Storage of personal data

Borealmere will store your information for as long as necessary for the purposes described in this policy, or as required by law, regulation, or authority.

If you have given consent, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension after renewed consent.

We regularly review stored information to ensure it is not kept longer than necessary.

9. Transfer of personal data to third countries or international organizations

Your personal data may be transferred to a third country (outside the EEA) or to international organizations. In such cases, Borealmere will implement necessary safeguards to ensure that the data is protected and that you retain your rights and effective remedies.

If you reside in the EEA (European Economic Area), such safeguards will apply if one of the following criteria is met:

• The transfer is to a third country or international organization that the European Commission has recognized as having an adequate level of data protection, pursuant to GDPR Article 45(3).
• The transfer is based on a legally binding and enforceable agreement between public authorities or bodies, pursuant to GDPR Article 46(2)(a).
• The transfer is based on standard data protection clauses adopted by the European Commission, pursuant to GDPR Article 46(2)(c). You can find these clauses on the European Commission's website.

If you would like more information about the safeguards we use when transferring personal data, you can contact us by email: [email protected]

10. Protection of personal data

We use technical and organizational security measures to protect personal data against unauthorized access, alteration, loss, or destruction. These measures are adapted to the risk associated with the processing.

We cannot guarantee absolute security for data transmission over the internet. Borealmere disclaims liability for indirect or incidental damages that may arise from data loss or unauthorized access beyond our reasonable control.

In some cases, we may be legally required to share information with public authorities. In such instances, our control over the protection of the information may be limited.

11. Links to third-party websites

The site may contain links to external websites or applications operated by third parties. Borealmere has no control over these and is not responsible for their processing of personal data. We recommend that you always read their privacy policies before providing any information.

12. Your rights regarding personal data

You have the right to request access to the information we process about you, request correction of errors, request deletion of data that is no longer necessary, and restrict or withdraw consent for certain processing.

Right of access

You have the right to obtain confirmation as to whether Borealmere processes personal data concerning you. If we do, you have the right to access the data and information about: purposes, categories of data, recipients (including in third countries), storage period, rights, the right to lodge a complaint, and the safeguards in place for transfers.

You may receive a copy of the data being processed. If you request additional copies, we may charge a reasonable fee. If the request is submitted electronically, you will generally receive the data in a commonly used electronic format.

The right of access shall not adversely affect the rights and freedoms of others. If this occurs, we may limit access or deny the request.

Right to rectification

You may request that Borealmere rectify inaccurate or incomplete information concerning you. If necessary, you may supplement it with a clarifying statement.

Right to erasure ("right to be forgotten")

You have the right to request the deletion of your data when it is no longer necessary for processing, when you withdraw consent, or when the processing is unlawful. We will respond in accordance with applicable law.

Right to erasure ("right to be forgotten")

This right applies if: (a) the personal data is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or third parties' legitimate interests, and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the data has been processed unlawfully; or (f) the data must be erased to comply with a legal obligation under EU or Norwegian law.

The right does not apply if processing is necessary (a) to comply with a legal obligation, or (b) for the establishment, exercise, or defense of legal claims.

Right to restriction of processing

You may request that we restrict the processing of your data if: (a) you contest the accuracy, for a period allowing us to verify; (b) the processing is unlawful, but you prefer restriction over erasure; (c) we no longer need the data, but you need it for legal claims; (d) you have objected to processing, pending verification of our legitimate interests; (e) the data is processed for direct marketing, including profiling.

If processing is restricted, the data may only be used with your consent, for legal claims, to protect the rights of others, or for reasons of important public interest.

Right to data portability

You have the right to receive personal data you have provided to us in a structured, commonly used, and machine-readable format. You may also request that the data be transferred directly to another controller, where technically feasible, and where processing is based on consent or contract and carried out by automated means.

Right to withdraw consent

You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to object

You may object to the processing of your data when processing is based on legitimate interests. This also applies to profiling. We will then stop processing, unless we demonstrate compelling legitimate grounds that override your interests and rights, or if processing is necessary for legal claims.

You may also object at any time to processing of data for direct marketing, including profiling related to such marketing.

Right to lodge a complaint with a supervisory authority

You may lodge a complaint with the Data Protection Authority or another supervisory authority within the EEA if you believe that the processing of your personal data violates the GDPR.

We will respond to requests to exercise rights within one month of receipt. If necessary, the deadline may be extended by up to two months, depending on the complexity of the matter and the number of requests. You will be informed of the reason for the delay.

Information regarding the exercise of rights will be provided free of charge, unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse the request.

Borealmere may request additional information to confirm your identity if we have reasonable grounds to doubt it.

13. Updates to this policy

We reserve the right to update this Privacy Policy. Changes will be posted on the site, and material updates will be communicated in a clear manner. Unless otherwise stated, changes take effect when the updated policy is published.