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
We are committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Regal Vestholm (the "Website").
We want you to be able to make informed decisions about how your Personal Data is used and processed. We use a range of methods to keep you appropriately informed, and where specific details are needed, we will provide them at the relevant time. We are also happy to address any questions you may have about applicable legal limitations.
1. The Scope
This policy explains what personal data the Company collects about individuals, and how that data is processed, shared with third parties, and secured.
1.2 This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified through a combination of additional information we hold or can reasonably access.
1.3 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect information from, or permit access to, anyone under 18. If we become aware that we hold information relating to a person under 18, we will delete it promptly.
2. What Personal Data Do We Have on You
When you access our services, channels, or website, we collect personal data. In certain instances, we may also ask you to provide personal data directly.
2.2 In other cases, we collect your personal data by analysing how our Services and service channels are used, or by receiving your information from our third-party partners.
3. No Requirement to Disclose Personal Information
You are not required to provide us with personal data. However, withholding it may prevent us from delivering the Services or from granting you access to the website.
4. What Personal Data We Collect
This includes information about your online activity log and traffic data, 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
The information collected is not personal information and cannot be used to identify you.
4.3 Personal data we receive from you: any personal data you choose to provide to us when connecting to a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party platforms to facilitate trade includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
Your personal data is processed by the company for the purposes set out in this section, in accordance with the applicable legal basis.
5.2 The Company may only process your personal data where a valid legal basis exists. The legal grounds on which the Company may rely to process your personal data are:
- By submitting personal data through this website, you consent to its processing for one or more specified purposes, including its transfer to a third-party trading platform.
- In some cases, processing personal data is necessary to serve the legitimate interests of the company or a third party — for example, to improve our services or defend legal claims.
- Processing must meet an obligation of law.
For more information on the processing carried out to protect legitimate interests, please contact us by email.
5.4 The following outlines the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
If you request it, we may share your personal data with third-party companies to facilitate access to digital trading.
You have consented to the processing of your personal data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal data is necessary to address any questions you may have about the Services.
Processing is necessary to support the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, or judicial obligations.
To ensure compliance with legal obligations, processing is required.
4. To Improve Our Services
We may use personal data to improve Our Services, including crash reports and malfunction data collected in connection with the Services.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
This includes back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is required to support the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.
8. To protect our assets, rights, and interests, and 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.
Processing is necessary to support the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party service providers, including hosting and storage providers, as well as companies that analyse user experience and IP address information.
6.2 You may also request that we share specific personal data about you with third-party trading platforms. Where you make such a request, we will provide the relevant personal data to those platforms. Your personal data shared in this way is governed by their respective privacy policies. Your personal data may be shared with more than one trading platform.
6.3 The Company may share Personal Data with related entities or business partners to enhance and improve the products and services provided to its customers.
Where necessary to protect the rights of third parties or their assets, the Company may disclose personal data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of assets, a merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may work with third-party services — such as advertisers and analytics providers — that operate on our website. These third parties may also use cookies or similar tracking technologies.
7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistics and analytics purposes.
7.3 Some cookies used on this website are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognise you as a returning user and allow you to resume your session.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and to navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and let you move between pages — including ones you've previously visited.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify you're logged in. They're deleted when you close your 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
These cookies persist until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect site performance data and improve the user experience, as well as to carry out analysis on our website.
Additional Information
Cookies store anonymous data that is not associated with any identified or identifiable natural person. Session cookies are removed when you close your browser. Other cookies remain valid indefinitely.
7.4 If cookies are blocked or removed, you'll need to adjust your browser settings. The links below cover the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some or all Website features and functions may not work as expected if this occurs.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
We will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for such longer periods as permitted by applicable law, regulations, or orders.
8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will share your data for a further 12 months.
We regularly review the personal data we hold to confirm it's no longer required.
9. International Transfers
9.1 Your personal data may be transferred to other countries or to international organisations. We take all necessary steps to protect your personal data and ensure you retain the ability to exercise your rights and access effective legal recourse.
These protections and safeguards apply to all residents of the EEA (European Economic Area):
- Transfers to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- This transfer is made under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
- This transfer was carried out in accordance with standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 We can provide details on the security measures used to protect your personal data when transferred to third-party countries or international organisations. To request this information, email: support@regalvestholm.com
10. Security of Personal Data
We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or modification.
We cannot guarantee that your Personal Data will be kept secure without error, nor do we accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.
10.3 Where we are required by legal or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these circumstances, we have no control over how those third parties protect your Personal Data.
10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 Our website may contain links to third-party websites and applications. These are not operated or supervised by the Company. We are not responsible for how such websites or applications collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.
Before accessing or using any third-party websites or apps, read their privacy policies carefully. Be mindful of any personal data you share with them.
12. Modifications to This Policy
This Policy may be updated at any time. If changes are made, we will notify you by posting the updated Policy on our website.
12.2 When we make significant changes to this Policy, we will notify you through appropriate channels and publish an announcement on our website.
Unless otherwise specified, any amendments to this Policy take effect upon publication of the revised version.
13. Your Rights
You have the right to request verification of the accuracy of your Personal Data we collect, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.
If you are an EEA resident, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.
13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. This right is subject to the rights and freedoms of others. Where fulfilling a request would infringe on another person's rights or freedoms, the Company may refuse or limit its response accordingly.
13.4 Right to rectification We may correct inaccurate Personal Data held about you. You have the right to request that incomplete Personal Data be rectified, having regard to the purpose for which it is processed.
13.5 Right to Erasure You may request erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no remaining legal basis to process; (c) you object, on grounds specific to your situation, to processing of your Personal Data that is based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to fulfil a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where such a restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or where there is a significant public interest within the European Union or a Member State.
13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used format. You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.
13.9 Right to withdraw consent You may withdraw your consent for Us processing Personal Data about you at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, you may submit a complaint to a supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that European Union and member state laws may limit the rights described in this section 13.
We will respond to your request, in line with the rights outlined in section 13 of this agreement, within one month of receipt. Where the nature or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.
Subject to the provisions of section 13 of the law, information requested under your section 13 rights will be provided at no cost. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act on such requests.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide a reasonable means of verifying their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Regal Vestholm 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@regalvestholm.com