Article 1: Identification of the Data Controller This Privacy Policy defines the rigorous data processing protocols maintained by Clover Wealthmere ("the Platform", "we", or "our"), with its registered office located at 3rd Floor, The Hive Building, 18 Sandyford Business District, Dublin 18, D18 XA42, Ireland. We act as a data controller in accordance with the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018. To ensure absolute data integrity, we have appointed a Data Protection Officer (DPO) reachable at [email protected].

Article 2: Categories of Personal Data Collected In accordance with the principle of data minimisation, we collect:

Identity Metrics: Full legal name, date of birth, nationality, and official government ID for mandatory KYC/AML verification.

Financial Telemetry: Source of funds, digital asset wallet addresses (public keys), and transaction history.

Digital Footprint: IP addresses, hardware specifications, and detailed interaction logs with our interfaces.

Article 3: Legal Basis for Processing Our collection and use of information are based on:

Contractual Necessity: Indispensable for the management of your account and the delivery of our services.

Statutory Obligations: Compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts.

Legitimate Business Interests: Proactive fraud prevention and strengthening of network security.

Explicit Consent: For personalised market analysis and non-essential analytical cookies.

Article 4: Advanced Security and Sovereignty

Encryption: All data at rest is stored using AES-256 cryptographic protocols.

Transmission: Secured via TLS 1.3 end-to-end encryption.

Hosting: Data is exclusively hosted on redundant and highly secure servers within the European Economic Area (EEA), ensuring total protection under EU data sovereignty laws.

Article 5: Retention and Your Rights We retain identity and financial records for a minimum period of five (5) to seven (7) years following account closure to satisfy Irish tax and anti-money laundering requirements. Under the GDPR, you possess the right to access, rectification, erasure, and portability of your data. Requests can be sent to [email protected]. You also have the right to lodge a complaint with the Data Protection Commission (DPC) of Ireland.