Privacy Policy

Last updated: 1 January 2026

This Privacy Policy explains how Kluisterdom ("we", "us") collects, uses, stores and protects personal data when you visit our website or use our platform. We process personal data in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations. Please read this policy together with our Terms of Service.

1. Who we are

Kluisterdom is the controller of the personal data described in this policy. You can contact us at Fenchurch Street 194, BS1 5LJ Bristol, United Kingdom, by email at [email protected], or by telephone on +44 20 7946 0412. For privacy enquiries, please mark your message "Privacy".

2. Personal data we collect

• Identity and contact data: name, email address and telephone number, where you provide them.
• Account data: login details, preferences and settings within the dashboard.
• Usage data: pages viewed, features used, approximate location derived from IP address, device type and browser information.
• Communications data: records of correspondence with our support team.

We do not ask you for passwords to external exchange or wallet accounts, and you should never share them with us.

3. How we use your data

We use personal data to create and administer accounts, provide the Services, respond to enquiries, maintain security, detect and prevent fraud, improve the platform, and comply with legal obligations such as anti-money laundering checks where they apply. Where we send marketing messages, we do so only with your consent or where the law otherwise permits, and you may opt out at any time.

4. Legal bases for processing

Our lawful bases are: performance of a contract with you; compliance with legal obligations; our legitimate interests in running, securing and improving the Services, balanced against your rights; and your consent, where we ask for it specifically, such as for optional marketing cookies.

5. Cookies

We use essential cookies to keep the site working and, with your consent, analytics cookies to understand how visitors use it. Details of the cookies we use, and how to manage them, are set out in our cookie preferences tool.

6. Sharing your data

We share personal data only where necessary with trusted service providers acting on our instructions, including hosting, analytics, customer support and payment processing providers. These providers are bound by written contracts and appropriate confidentiality obligations. We may also disclose data where required by law, by a court order, or to protect the rights and safety of users. We do not sell your personal data.

7. International transfers

Some of our providers may process data outside the United Kingdom. Where this happens, we ensure that appropriate safeguards are in place, such as UK-approved standard contractual clauses or an adequacy regulation, in line with UK data protection law.

8. Retention

We keep personal data only for as long as necessary for the purposes described in this policy. Account data is generally retained for the life of your account and for a further period needed to meet legal, tax and accounting requirements. Usage logs are kept for a limited period and then deleted or aggregated.

9. Security

We apply technical and organisational measures appropriate to the risk, including encryption in transit, access controls, role-based permissions and regular reviews of our systems. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

10. Your rights

Subject to certain exemptions, you have the right to access your personal data, to have inaccurate data corrected, to request erasure, to restrict or object to processing, to request data portability, and to withdraw consent at any time. You may also lodge a complaint with the Information Commissioner's Office (ico.org.uk). We will respond to valid requests within one month, extendable where the law allows.

11. Children

The Services are not directed at anyone under 18 and we do not knowingly collect personal data from children. If you believe a child has provided us with data, please contact us so that we can delete it.

12. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page shows when it was last revised. Material changes will be notified through the Services or by email.