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 Boldequitor (the "Website").
We want you to be fully informed about how your Personal Data is used and processed. We use a range of methods to keep you informed and will provide specific details when relevant. We're also happy to address any questions about applicable legal limitations.
1. The Scope
1.1 This policy sets out the types of personal data the Company collects about individuals, and how that data is processed, shared with third parties, and kept secure.
1.2 This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly, or 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 the age of 18. We do not knowingly collect information from, or permit the use of our services by, anyone under 18. Should we become aware that any such information has been collected, 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 request personal data from you 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 third-party partners.
3. No Requirement to Disclose Personal Information
You are not required to provide us with any 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
4.1 This includes your online activity log and traffic data, such as:
- 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 data 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 with a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party platforms to facilitate trading: this 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:
- You have consented to the processing of your personal data for one or more specified purposes. This applies where you submit personal data via the Website for transfer to a third-party trading platform.
- In some cases, the Company or a third party may need to process personal data to pursue legitimate interests — such as improving our Services or defending legal claims.
- Processing must meet an obligation of law.
For more information about the processing carried out to safeguard legitimate interests, please contact us by email.
5.4 Below is a list of 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 collect personal data from you and share it 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
We use your personal data to address any questions you may have about our Services.
Processing is required to serve the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, and 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 is necessary to pursue the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing of personal data may be necessary to pursue 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 serve 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 is necessary to serve the legitimate interests of the Company or those of a 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 pursue 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, IP address data processors, and user experience analytics providers.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will pass the relevant Personal Data you have provided to us to those platforms. Your Personal Data will then be governed by their respective privacy policies. Please be aware that 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 where this supports the development and improvement of the products and services provided to customers.
6.4 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 group company in connection with a transaction (including the transfer or sale of Company or group assets), or as part of any merger, restructuring, consolidation, or insolvency event affecting the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may work with third-party service providers, such as advertisers and analytics companies, who operate on our website. These third parties may also use cookies or similar technologies.
7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your preferences and browsing behaviour, personalise your experience, and remember your settings. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. These are used to recognise you as a returning user and help you resume your visit to the website.
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 us to deliver the information, products, and services you've asked for, and allow your device to download and stream data — so you can browse the site, use its features, and return to previously visited pages.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify that you are logged in. They are deleted automatically when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies recognise you each time you visit our site and store 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 statistical data about site performance and to carry out analysis that helps us improve your experience.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable individual. Some cookies are deleted when you close your browser; others remain valid indefinitely.
7.4 If you need to block or remove cookies, you can do so by adjusting your browser's settings. The links below cover the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that if this occurs, some or all of the Website's functions and features may not work as expected.
Online Tracking Notice: This service does not currently recognise 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 longer periods where permitted by applicable law, regulation, or order.
8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will do so for a further 12 months.
We periodically review the personal data we hold to confirm it is no longer required.
9. International Transfers
9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect your personal data and ensure that individuals can exercise their rights and access effective legal remedies.
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, in accordance with 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).
- The transfer was made in accordance with standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide details of the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, contact us at: support@boldequitor.com
10. Security of Personal Data
10.1 We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that your Personal Data will be kept secure without error, nor can we accept liability for any indirect, 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 reasonable control.
10.3 Where we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over how those third parties handle or 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 The website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for the collection or processing of personal data by those sites or applications. This Policy does not apply to any actions taken through them.
When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. You should also take care when sharing any personal data with them.
12. Modifications to This Policy
12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised 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, to have any inaccuracies corrected, and to request deletion of Personal Data we no longer require. You may also restrict the scope or type of processing applied to your Personal Data.
If you are a resident of the EEA, please refer to this page for details on your rights in relation to your personal data. To exercise any of these rights, please contact us at the email address below.
13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where this is confirmed, you have the right to access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Where requested, data will be provided electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another individual, the Company may refuse to comply or limit the extent to which it does so.
13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You may also request the rectification of incomplete Personal Data relating to you, taking into account the purpose for which it is processed.
13.5 Right to Erasure You may request the erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data have been unlawfully processed; or (f) the 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 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 substantial 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 on a contract to which you are a party, you have the right to receive your Personal Data in a structured, commonly used format and to request that it be transferred directly to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure, and it does 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 on the basis of your consent prior to its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. European Union and member state law may limit your rights in relation to your Personal Data, as set out in this section 13.
We will respond to requests made under Section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity and volume of requests received. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.
Subject to section 13 of the law, information provided in response to your rights requests will be supplied free of charge. Where a request is manifestly unfounded or excessive — in particular where requests are repetitive — we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may decline to act.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that individual to provide suitable means of verifying their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Boldequitor 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@boldequitor.com