Privacy Policy Last updated: 24/02/2024

We are fully committed to safeguarding your Personal Data and ensuring your privacy is protected.

This Privacy Policy is crafted to enlighten you about the methods We employ to manage, collect, store, and utilize the information you provide when interacting with the Vortex App website (the “Website”).

We pledge to uphold the following principles:

• To maintain transparency in the collection and processing of your Personal Data:

Our priority is to ensure you are consistently well-informed, empowering you to make knowledgeable decisions regarding the use of your Personal Data on our Website or when engaging with third-party trading platforms. We implement various strategies to deliver relevant information about how your Personal Data is processed, ensuring it reaches you promptly and accurately.

Furthermore, should there be any requirement for you to receive specific information, We will ensure it is provided to you at the appropriate time and place.

We welcome any questions you might have and are ready to provide the clarifications you need, within legal boundaries. You can reach out to Us by sending an email to the following address: support@

• To process your Personal Data strictly for the purposes outlined in this Policy:

We may process your Personal Data for purposes including, but not limited to, making the Website available to you andprovide you with access to third-party trading platforms (the “Services”), aiming to enrich the user experience on the Website, enhance the Services (including the Website), safeguard Our rights and interests, carry out business and administrative activities that support the delivery of the Services to Website users, and/or comply with any legal and/or regulatory obligations.

Additionally, We will process Personal Data about you to better understand your personal needs and preferences.

• To invest significant resources to honor your rights concerning Personal Data about you:

We dedicate considerable resources to enable you to exercise your rights as a data subject. You are welcome to contact Us anytime to review Personal Data about you, request modifications, erase it, stop its use for certain purposes or altogether, or transfer it to yourself or a third party. We will comply with your requests in accordance with the law.

•To safeguard Personal Data about you:

While We cannot guarantee absolute protection of the Personal Data about you, We assure you that We use and will continue to employ a comprehensive range of methods and measures designed to ensure the Personal Data about you is secure.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy outlines the types of Personal Data the Company gathers about individuals, and the methods it employs to collect, use, share with third parties, secure, and process it, among other activities.

In this Policy, “Personal Data” denotes any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, with additional information that We possess or have access to.

In this Policy, the “processing” of Personal Data includes any operation or series of operations conducted on Personal Data, such as collection, recording, organization, structuring,storage, modification or adaptation, retrieval, consultation, usage, transmission, dissemination or other forms of making available, alignment or combination, restriction, deletion, or destruction of Personal Data.

Our Services cater to a general audience and are not designed for individuals under the age of 18. We do not intentionally gather or request information from those under 18 or knowingly permit such individuals to utilize our Services. Should we discover that we have collected information about a minor, we will promptly take reasonable measures to erase such information.

2. When Do We Collect Personal Data About You?

We gather Personal Data about you each time you engage with the Services, interact with our service channels, or navigate the Website. Sometimes, you will directly provide Us with the Personal Data, while other times, we will obtain Personal Data about you by analyzing your interaction with Our Services and/or service channels or receiving your data from our third-party partners.

3. No Obligation To Provide Personal Data To The Company And Its Implications

You are under no obligation to supply Us with any Personal Data about yourself. However, in certain cases, not providing such Personal Data may hinder our ability to offer you the Services, limit your access to the Website, and/or cause disruptions in the functioning of the Services and the Website.

4. What types of Personal Data do We collect? Personal Data We collect upon each browsing onto the Website:

This information includes online activity logs, traffic details (including, but not limited to, IP address, time and date of access, web and mobile pages visited, language used, software crash reports, and type of browser used, along with information regarding the device you utilized). Some of this information may not personally identify you, and therefore may not be classified as Personal Data.

Personal Data We receive from you: any Personal Data you voluntarily provide to Us when engaging with a third-party trading platform through Vortex App.

Personal Data You Provide Specifically for Trading Platform Submission: This information encompasses your full name, phone number, and email address.

5. Objectives for Processing Personal Data and Legal Grounds

The Company handles your Personal Data for one or more of the objectives outlined in this section, adhering to the suitable legal basis.

We ensure your Personal Data is processed only when there is a legitimate legal basis. The legal grounds on which the Company might process your Personal Data include:

• You have consented to the processing of your Personal Data for one or more specific purposes. This applies when you willingly provide your details via the Website, enabling us to share them with third-party trading platforms.
• Processing is necessary for the legitimate interests pursued by the Company or a third party. For instance, enhancing Our Services or defending legal claims.
• Processing is essential for compliance with a legal obligation that the Company must adhere to.

If you seek further information on how your Personal Data processing aligns with the legitimate interests of Vortex App or any external party, feel free to contact us via email at any time.

Below, we offer a summary of the reasons we might process your Personal Data, along with the legal grounds for these actions:

	Purpose	Legal Basis
1	To facilitate the sharing of your information with third parties upon your request for engaging in digital and trading activities. We might gather your Personal Data to transmit it to third parties, should you explicitly request this service.	You have provided consent for your Personal Data to be processed for one or more specified purposes.
2	To address your inquiries, requests, and/or complaints Processing your Personal Data is essential to respond to any questions you have regarding your utilization of our Services.	Processing is necessary for the legitimate interests pursued by Vortex App or a third party.
3	To adhere to any legal duties or judicial or administrative directives We handle your Personal Data to fulfill our numerous legal responsibilities.	Processing is crucial for meeting a legal obligation that the Company is required to comply with.
4	To enhance Our Services We might utilize your Personal Data to refine Our Services. This processing could include, among other things, any crash logs or malfunction reports related to Services.	Processing is essential for pursuing the legitimate interests of the Company or a third party.
5	To deter fraud and misuse of Our Services	Processing is essential for pursuing the legitimate interests of the Company or a third party.
6	To execute and sustain various activities supporting the delivery of Our Services Such activities encompass back-office operations, business development initiatives, strategic planning, oversight frameworks, etc.	Processing is essential for fulfilling the legitimate interests of the Company or a third party.
7	To conduct analysis, including statistical evaluations We employ a range of analytical tools (including statistical ones) to inform decisions on various matters.	Processing is essential for fulfilling the legitimate interests of the Company or a third party.
8	To safeguard Our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims We may handle Personal Data concerning you to safeguard Our interests, rights, and assets, or those of third parties, in accordance with any law, regulation, or agreement, including any of Our terms, conditions, and policies.	Processing is essential for fulfilling the legitimate interests of the Company or a third party.

6. Transfer Of Personal Data To Third Parties

Vortex App may also share your Personal Data with third-party service providers, such as those offering storage and hosting, IP address information, user experience analysis, and other analytical, technical, and diagnostic services.

Additionally, if you request, we can forward certain Personal Data to third-party trading platforms on your behalf. In such scenarios, we will transmit the Personal Data you provide for this purpose to these third parties, who will then handle your data in accordance with their own privacy policies. Your Personal Data might be shared with multiple third-party trading platforms.

Vortex App might also share your Personal Data with its affiliated entities and business partners, which supply resources that help the company enhance and elevate the quality of its services and products for users.

Your Personal Data might be disclosed to governmental, local, official, and regulatory authorities if such disclosure is necessary to safeguard our interests, rights, and assets, as well as those of third parties, including for the initiation, exercise, or defense of legal claims.

Furthermore, we may reveal your Personal Data to prospective buyers, investors, or lenders of Vortex App and/or any entity within our corporate group. This may also occur during any similar transactions, such as asset sales, mergers, reorganizations, consolidations, or bankruptcies involving Vortex App and/or any affiliated companies.

7. Cookies and Third-Party Services

We might employ certain third-party services, like analytics companies or advertisers on our website, which may also use cookies or similar technologies. These practices and providers are governed by their own policies.

A cookie, which is a small text file, is installed on the device through which you visit or access the website. These cookies allow us to gather information about you and your behavior in order toenhance your user experience by remembering your preferences and settings. We tailor and provide products and services that align with your interests. Additionally, cookies may be utilized to gather statistics and conduct analytics.

Some cookies we deploy are session cookies, which are temporarily stored on your device and remain active until you close your web browser. Others are persistent cookies, which stay on your device even after you stop browsing the website, aiding in recognizing you as a returning visitor on your next visit.

Types of cookies:

The cookies we use are categorized based on their functionality as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are indispensable for you to navigate the website and access features you have requested. They are employed to deliver the content, products, and services you seek from us. Such cookies are crucial for enabling your device to download or stream information, facilitating seamless navigation around the website, utilizing its features, and revisiting pages you have previously accessed.	These cookies gather personal data about you, such as your username and last login date, and confirm your status as logged into the website. These cookies vanish as soon as you shut down your web browser (session cookies).
Functionality Cookies	These cookies help recognize you upon your return to the Website, enabling Us to recall your selections and preferences.	These cookies persist beyond the closing of your web browser, remaining active until their designated expiration.
Performance Cookies	These cookies gather collective statistics about the Website's performance to evaluate and enhance it, ensuring a superior user experience. Moreover, they facilitate analytical activities on the Website.	These cookies gather anonymous data not linked to any identified or identifiable individual. The validity of these cookies varies; some are erased upon closing your browser, while others may last indefinitely.

Blocking and Removal of Cookies

You have the option to adjust your browser settings to block or delete certain or all cookies. Below are links to instructions for doing this on some popular web browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware, however, that doing so may result in some or all of the Vortex App's features and functionalities not operating as intended.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

The Company will keep your Personal Data for the duration necessary to fulfill the processing purposes outlined in this Policy, or longer if required by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for a period of 12 months, and with your consent, we may extend this for an additional 12 months.

To ensure that your Personal Data is not retained longer than necessary, we conduct periodic reviews to determine if any data can be securely erased.

9. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data may be transferred to a third country (i.e., outside your residence jurisdiction) or to international organizations. In such cases, the Company will implement appropriate safeguards to protect your data and ensure enforceable rights and effective legal remedies for data subjects are available.

If you are a resident of the EEA (European Economic Area), please be assured that these protections will be in place if any of the following conditions are met:

• The transfer is directed to a third country or an international organization that the EU Commission has recognized as providing a sufficient level of protection for Personal Data transferred to it, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
• The transfer occurs under a legally binding and enforceable agreement between public authorities or bodies, as per Article 46(2)(a) of the GDPR; or
• The transfer adheres to standard data protection clauses adopted by the EU Commission in line with Article 46(2)(c) of the GDPR. You can review the clauses adopted by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You are welcome to request details from the Company about the safeguards it employs to protect the Personal Data about you that is transferred to a third country or an international organization. Simply send an email to the following address: support@

10. Protection Of Personal Data About You

We deploy suitable technical and organizational measures to ensure a high level of security for Personal Data, considering the risks posed by processing, especially from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we strive for excellence, we cannot promise flawless performance concerning the privacy of your Personal Data. We will not be liable for any indirect, incidental, consequential, or punitive damages related to the use or release of Personal Data about you, including but not limited to, disclosure of Personal Data due to transmission errors, unauthorized third-party access, or other causes beyond our reasonable control.

Due to legal or other obligations outside our control, we may be required to transfer Personal Data about you to third parties,entities like public authorities. In such cases, our ability to control the protection level provided to your Personal Data by these third parties is limited.

The transfer of Personal Data over the internet is inherently insecure. As such, the Company cannot guarantee the security of your Personal Data when it is transmitted to Us online.

11. Links To Third-Party Websites

The Website may feature links to third-party websites and/or applications. The Company does not govern these websites and applications, nor do we oversee the collection and/or processing of your Personal Data by them. We are not accountable for these websites and applications, or their privacy and data protection practices. This Policy does not cover any actions undertaken via these websites and/or applications.

We advise that you thoroughly review the privacy policies of such third-party websites and/or applications before utilizing them or sharing any Personal Data.

13. Your Rights Concerning Your Personal Data

Generally, you are entitled to request confirmation from Us regarding the collection of your Personal Data, to review this data, to rectify it if necessary, and to request its deletion if it is no longer needed by Us. You may also limit your consent to specific processing activities of your Personal Information.

If you are a resident of the EEA, please read the section below:

You are entitled to certain rights regarding your Personal Data. To exercise these rights, you may submit a request to the following email address:

Right of access

You are entitled to obtain confirmation from the Company regarding whether your Personal Data is being processed, and if so, to access the Personal Data along with the followinginformation: (1) the objectives behind the processing; (2) the types of Personal Data involved; (3) the recipients or groups of recipients to whom the Personal Data has been or will be shared, particularly those in countries outside the European Economic Area (EEA) or international bodies; (4) if feasible, the anticipated duration for storing the Personal Data, or if not, the criteria used to determine this duration; (5) the right to request the Company to correct or delete Personal Data or limit its processing, or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data was not collected directly from you, any available information about its source; (8) the presence of profiling; and (9) if Personal Data is transferred to a country outside the EEA or an international organization, the appropriate safeguards concerning the transfer.

The Company will provide a copy of the Personal Data under processing and may impose a reasonable fee for any additional copies you request. If your request is made electronically, and unless specified otherwise, the information will be provided in a widely-used electronic format.

The right to obtain a copy of the Personal Data should not compromise the rights and freedoms of others. Therefore, if fulfilling the request would harm the rights and freedoms of others, the Company might limit or deny your request.

Right to rectification

You have the right to have the Company correct any inaccurate Personal Data about you. Considering the purposes of the processing, you are also entitled to have incomplete Personal Data about you completed, including through a supplementary statement.

Right to erasure

You may exercise this right if: (a) the Personal Data is no longer necessary for the purpose it was collected or processed; (b) you withdraw your consent on which the processing relies, and there is no other legal basis for processing; (c) you object, based on your specific situation, to the processing of your Personal Data on grounds of legitimate interests pursued by us or a third party, and there are no overriding legitimate grounds for processing; (d) you object to the processing of your Personal Data for direct marketing purposes; (e) thePersonal Data has been processed unlawfully; or (f) the Personal Data must be erased to fulfill a legal obligation under European Union or Member State law applicable to the Company.

This right does not apply when processing is necessary (a) to comply with a legal obligation under European Union or Member State law that the Company is subject to; or (b) for the establishment, exercise, or defense of legal claims.

Right to Restrict Processing

You have the right to request that the Company restricts the processing of your Personal Data under the following conditions: (a) you contest the accuracy of your Personal Data, allowing the Company time to verify it; (b) the processing is unlawful, and you prefer to restrict the use of your Personal Data rather than erasing it; (c) the Company no longer requires your Personal Data for processing, but you need it to establish, exercise, or defend legal claims; (d) if processing your Personal Data is necessary for the legitimate interests pursued by the Company or a third party, unless we demonstrate overriding compelling legitimate grounds, or for legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling related to such marketing.

If processing your Personal Data has been restricted following your request, except for storage, it will only be processed with your consent, or for establishing, exercising, or defending legal claims, protecting another's rights, or for significant public interest reasons of the European Union or a Member State.

Right to Data Portability

You have the right to receive your Personal Data, which you've provided to the Company, in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another entity if processing is based on your consent or a contract you're part of, and if processing is automated.

When you decide to use your data portability rights, you have the option to transfer your Personal Data directly from the Company to another entity, if technically feasible. This right does not interfere with your or the Company's rights regarding data deletion. Additionally, exercising this right must not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

You can withdraw your consent for us to process your Personal Data at any time. This action will not affect the legality of any processing carried out before your withdrawal.

Right to Object

You have the right to oppose the processing of your Personal Data at any point, especially if it pertains to your specific situation and when the processing is based on the legitimate interests of the Company or a third party. This includes any profiling related to these interests. Upon your objection, we will cease processing your Personal Data unless we can present compelling legitimate reasons for the processing that outweigh your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You also possess the right to reject the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to Lodge a Complaint with a Supervisory Authority

You are entitled to file a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights and freedoms of individuals concerning the processing of Personal Data within the European Union.

Your rights concerning your Personal Data as described in this section 13 may be limited by European Union or Member State law to which the Company is subject.

We will provide you with the requested information according to your rights as described in this section 13 without undue delay and, in any event, within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested according to your rights as outlined in this section 13 will be provided free of charge unless stated otherwise in this section 13. Where requests are manifestlydeemed unfounded or excessive, particularly due to their repetitive nature, we may either (a) impose a reasonable fee, considering the administrative expenses involved in providing the requested information or communication, or (b) decline to fulfill the request.

Vortex App may ask you to furnish additional information necessary to verify your identity in order to process your request as per your rights described in this section 13, should we have reasonable doubts regarding the identity of the individual making the request.

12. Modifications To This Policy

We may revise, from time to time, the provisions of this Policy. Whenever we make changes to this Policy, we will notify you by posting the updated Policy on the Website. Furthermore, when significant changes are made, we will endeavor to notify you through communication methods we find reasonably suitable to inform you of such changes and by displaying a notice on the Website. Unless specified otherwise, all modifications will become effective upon publication of the updated Policy on our Website.