Marble Zinsara

TABLE OF CONTENTS

  • 1. The Scope
  • 2. What Personal Data Do We Have on You
  • 3. No Requirement to Disclose Personal Information
  • 4. What Personal Data We Collect
  • 5. Legal Basis and Reasons for Processing of Personal Data
  • 6. Transfer of Personal Data to Third Party
  • 7. Cookies and Services from Third Parties
  • 8. Retention of Personal Data
  • 9. International Transfers
  • 10. Security of Personal Data
  • 11. Hyperlinks to Third Party Websites
  • 12. Modifications to This Policy
  • 13. Your Rights

Privacy Policy

Last updated: 15.07.2026

We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy. This Privacy Policy explains how we collect and store the information you provide through the Marble Zinsara website (the "Website").

We want you to have the information you need to make informed decisions about how your Personal Data is used and processed. We use a range of methods and processes to provide relevant information clearly and at the right time. Where we consider further detail is needed, we will provide it when appropriate. We are also happy to answer any questions you may have, subject to any legal limitations.

By using our Website, you acknowledge that you have read and agree to this Privacy Policy. If you have any questions, please contact us at support@marblezinsara.com

1. The Scope

1.1 This policy explains what types of Personal Data the Company collects about individuals, how it is used, when it may be shared with third parties, and the measures in place to keep it secure.

1.2 This Policy applies to information relating to an identified or reasonably identifiable individual. An identifiable individual is someone who can be recognised either directly, or indirectly when combined with other information we hold or can access.

1.3 In this Policy, "processing" means any activity that involves the use or collection of Personal Data, including its handling, organisation and storage.

1.4 Our services are intended for a general audience and are not designed for anyone under 18 years of age. We do not knowingly collect information from anyone under 18 or permit them to use our services. If we become aware that we hold information about a child, we will delete it as soon as reasonably practicable.

2. What Personal Data Do We Have on You

2.1 When you use our services and channels, or visit our website, we collect Personal Data. In some circumstances, we may ask you to provide your Personal Data.

2.2 In some cases, we collect your Personal Data by analysing how you use our Services or service channels, or by obtaining your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide Us with any Personal Data. However, in some circumstances, if You choose not to provide Personal Data, We may be unable to deliver the Services or users may be unable to access the website.

4. What Personal Data We Collect

4.1 This includes details of your online activity log and information about your traffic, including:

  • IP address
  • Date of access and time of access
  • Language you used
  • Software crash logs
  • Type of browser used
  • Information regarding the device that you utilised

4.2 The information we collect is not personal information and cannot be used to identify you.

4.3 Personal information we receive from you: any personal information you choose to provide to Us when you connect, through Us, to a third-party online trading platform.

4.4 Personal information you provide directly to third-party platforms to enable trading: this includes your full name, address, phone number and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 The company processes your Personal Data for the purposes set out in this section and in line with the applicable legal basis.

5.2 The Company cannot process your Personal Data without a lawful basis. The legal grounds on which the Company may process your Personal Data are as follows:

  • You have consented to the processing of your Personal Data for one or more purposes. This applies when you provide personal information through the Website so that we can pass it on to a third-party trading platform.
  • The Company or a third party may need to process data where this is necessary for their legitimate interests, such as improving Our Services or responding to legal claims.
  • Processing must meet an obligation of law.

5.3 For more information about the processing required to protect legitimate interests, please contact us by email.

5.4 The following sets out the reasons and legal bases on which we may use the information you provide to us:

Scope

Legal Basis

1. To share your personal information with third parties at your request so you can access digital trading
If you request this, we may ask you to provide Personal Data so we can pass it on to third-party companies.

You have consented to the processing of your Personal Data for one or more purposes.

2. To respond to your enquiries, questions or concerns
We need your Personal Data so we can address any questions you may have about the Services.

Processing is necessary to support the Company’s legitimate interests or those of a third party.

3. Personal Data is processed to comply with any legal, administrative or judicial obligation or requirement.

To ensure compliance with legal obligations, processing is required.

4. To improve Our Services Personal
We may use Personal Data to improve Our Services. This includes, among other things, any crash reports or malfunction reports we collect in connection with the Services.

The Company’s legitimate interests, or those of a third party, need to be processed.

5. To stop fraud and misuse of Our Services.

Processing is necessary to support the Company’s legitimate interests or those of a third party.

6. To carry out and manage activities required for the delivery of Our Services
These activities may include back-office operations, business development, strategic decision-making, oversight processes and similar functions.

Processing is necessary for the legitimate interests of the Company or a third party.

7. To carry out analysis, including statistical analysis
We use a range of analytical methods, including statistical techniques, to support decision-making on various matters.

The Company’s legitimate interests, or those of a third party, need to be processed.

8. To protect our assets, rights and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant conditions, terms or policies.

The Company’s legitimate interests, or those of a third party, must be processed.

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, IP address data providers, and providers of user experience analytics.

6.2 You may also ask us to provide your specific Personal Data to third-party trading platforms. In these circumstances, we will share the Personal Data you have provided to Us with those third-party trading platforms. Any use of your Personal Data will be governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners where necessary. This helps the Company access the resources it needs to enhance and improve the products and services it provides to its customers.

6.4 Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local or other relevant authorities.

6.5 We may also disclose your Personal Data to prospective investors or purchasers, or to lenders to the Company or any other entity within the corporate group, if a relevant transaction is proposed or carried out (including the transfer or sale of assets owned by the Company or any other group entity), or as part of a merger, restructure, consolidation or insolvency process involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, including advertising providers on our website and analytics providers. These companies may also use cookies or similar technologies.

7.2 Cookies are small text files stored on your device each time you visit or access the website. They help us understand your preferences and browsing behaviour so we can improve your experience, remember your settings, and tailor the products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period of time after your browser is closed. They help the Website recognise you as a returning user and allow you to return to the website more easily.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are essential for accessing the features you’ve requested and moving around our website. We use cookies to deliver the information, products and services you’ve asked for.
They are needed so your device can download and stream data. This allows you to browse the website, use its features, and return to pages you’ve visited before.

Additional Information

Cookies may collect Personal Data, including your username and the date of your last login, to confirm that you’re logged in to the site. These are deleted when you close your web browser (session Cookies).

The type of cookie

Functionality Cookies

Scope

Cookies help us recognise you each time you visit our site and remember your preferences.

Additional Information

They remain in place until their expiry date and stay saved even after the browser is closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical information about the site’s performance and help improve it. They also allow Us to analyse activity on our website.

Additional Information

Cookies store anonymous information that is not linked to an identified or identifiable individual. Some cookies are deleted when you close your browser, while others remain valid indefinitely.

7.4 Cookies may be blocked or deleted. To block or remove cookies, you'll need to change your browser settings. Below are links to guide you through the process for some of the most commonly used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please note that if this occurs, some or all Website functions and features may not operate as expected.

Online Tracking Notice: This service does not currently respond to do-not-track signals.

8. Retention of Personal Data

8.1 The Company will keep your Personal Data for as long as needed to fulfil the purpose for which it is processed, as set out in this Policy, or for longer where permitted by applicable law, regulations, policies, or relevant orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to make sure it is no longer required.

9. International Transfers

9.1 Your personal information may be transferred overseas (that is, your personal data may be disclosed to recipients in other countries or to international organisations). The Company takes all reasonable steps to protect the Personal Data you provide and to ensure you are able to exercise your rights and access effective legal remedies.

These protections and safeguards are available to anyone living in the EEA (European Economic Area):

  • Transfer to an overseas recipient or international organisation where the relevant authority has determined that adequate protection is in place for Personal Data transferred to that recipient.
  • The transfer is carried out under a legally binding and enforceable agreement between public bodies or authorities within the meaning of Article 46(2)(a)
  • The transfer was carried out in accordance with standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR

9.3 The Company can provide details of the security measures it uses to protect your Personal Data when it is transferred to overseas countries or international organisations. Please email: support@marblezinsara.com

10. Security of Personal Data

10.1 We have implemented suitable organisational and technical measures to protect Personal Data, including safeguards against its accidental or unlawful destruction, loss or alteration.

10.2 While we take reasonable steps to protect your Personal Data, we cannot guarantee that its security will be maintained without interruption or error. We are also not liable for any indirect, incidental or consequential loss or damage arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed as a result of transmission errors, unauthorised access by a third party, or any other circumstances beyond our control.

10.3 Where we are legally required to do so, or where circumstances outside our control make it necessary, we may disclose your Personal Data to third parties, including public authorities. In these circumstances, we are unable to control how those third parties protect your Personal Data.

10.4 Personal Data cannot be transferred over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website may include links to third-party websites and applications. These websites and applications are not under the Company’s control, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through those websites or applications.

11.2 Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also suggest considering this before providing any Personal Data to that third party.

12. Modifications to This Policy

12.1 We may update this Policy at any time. If we do, we will notify you by publishing the revised Policy on our website.

12.2 In addition, if we make any material changes to this Policy, we will endeavour to notify you by the means we consider appropriate and will post a notice on our website.

12.3 Unless stated otherwise, any changes will take effect once the updated Policy has been published.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we do not need to retain. You may also request that we limit the types of processing applied to your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the personal information you provide to us. To exercise any of these rights, you may email us at the address below.

13.3 Access rights The Company may verify the accuracy of the Personal Data it processes about you. Where your Personal Data is being processed, you have the right to access it. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be provided electronically. Your right to access Personal Data must not adversely affect the rights and freedoms of others. If a request would prejudice another person’s rights or freedoms, the Company may refuse the request or limit the extent to which it can comply.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data relating to you be corrected, taking into account the purpose of the processing.

13.5 Right to Erasure This right applies in the following circumstances: (a) Personal Data are no longer needed for the purpose for which they were collected or otherwise processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by Us or by a third party; (e) Personal Data have been processed unlawfully; or (f) Personal Data must be erased 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 requiring processing under applicable law; or (b) for the establishment, exercise or defence of legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request a restriction, your Personal Data may then only be retained with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another individual, or where there is an important public interest reason under applicable law.

13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to receive the Personal Data you have provided to the Company and to review that data. You are also entitled to request that your Personal Data be transferred directly by the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. This right does not override the rights or freedoms of any other person.

13.8 Right to object You may object at any time to the use of your Personal Data where the processing is based on the legitimate interests of the Company or a third party. This right also applies to profiling carried out on that basis. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue to process it unless you show that your rights, freedoms or interests override those grounds, or that the processing is required for the establishment, exercise or defence of legal claims. In relation to direct marketing, you have the right to object at any time to the processing of your Personal Data.

13.9 Right to withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the legality of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to make a complaint to the relevant supervisory authority. You may submit a complaint to a supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data. Applicable laws may limit your rights in relation to your Personal Data, as set out in this section 13.

13.10 We will provide the information you request in accordance with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature of your request and the volume of requests received. If an extension applies, we will let you know within one month of receiving your request and explain the reasons for the delay.

13.11 Provided this does not conflict with the requirements of section 13 of the law, any information you request in exercising your rights under section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where it is repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

13.12 If we have any doubts about the identity of the person who submitted your request, we may ask the person making the request to provide reasonable proof of identity.

Please read this Privacy Policy together with our Term Of Use and Risk Disclosure.

Marble Zinsara 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@marblezinsara.com