Privacy Policy

1. The Scope

1.1 This policy explains the type of Personal Data the Company collects on individuals, and how it processes, shares with third parties, and secures that data.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through a combination of additional information we hold or are able to access.

1.3 The Policy defines "processing" as any operation that uses or collects Personal Data, including its management, structuring, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we discover that we hold any information relating to a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access the service and channels or visit our website. In certain instances, we may request your Personal Data.

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

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. In certain circumstances, however, withholding such data may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.2 The information we collect 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 you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trades: 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, in accordance with the applicable legal basis.

5.3 Contact us by email for more details on the processing necessary to protect our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, including IP address information and analysis of user experiences.

6.2 You can also ask us to share specific Personal Data about you with third-party trading platforms. In these cases, we will provide the Personal Data you give to us to those third-party trading platforms. Use of your Personal Data is then 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. This provides the resources needed to develop and improve the products and services offered to its customers.

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

6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, where such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or similar technology.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services on offer. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily stored on your device and expire once you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. These help the Website recognise you as a returning user and make it easier for you to return.

7.5 Please note, however, that if this happens, some or all of the Website's functions and features may not work as you expect.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose for which it is processed, as described in this Policy, or for longer where permitted by applicable laws, regulations, policies, and orders.

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

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to a third country or to international organisations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 You may request information about the security measures we use to protect Personal Data transferred to third countries or international organisations. Email us at: support@royalkapithorne.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to safeguard Personal Data, including protection against the accidental or unlawful destruction, loss or alteration of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held accountable 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 access by a third party or any other cause beyond our control.

10.3 Where 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 such cases, we cannot control the level of security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.

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 control. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to any actions taken through them.

11.2 Before you visit any third-party website or app, we recommend reviewing its privacy policy before you decide to access or use it, and exercising care when sharing any Personal Data with it.

12. Modifications to This Policy

12.1 This Policy may change at any time. Where we make changes, we will notify you by posting the updated Policy on our website.

12.2 We will also notify you of any significant changes to this Policy through methods we consider appropriate, and will publish an announcement on our website.

12.3 Unless stated otherwise, any amendments take effect once the revised Policy is published.

13. Your Rights

13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the scope and 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 information you provide in relation to your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access The Company can confirm whether your Personal Data is being processed. If it is, you may 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 you request it, the data will be supplied electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with it or limit the extent to which it does so.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You may request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by 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 the processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or Member State law; or (b) to establish, exercise or defend legal rights.

13.6 Restrictions on processing If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request that Personal Data be restricted, it may only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights of another natural person, or for reasons of 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 the Personal Data you have provided to the Company. You may also request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights and freedoms of others.

13.8 Right to object You have the right at any time to object to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we can establish compelling legitimate grounds for the processing, we may continue to process your Personal Data unless you can demonstrate that your rights, freedoms, or interests override those grounds, or that the processing is necessary for the exercise, establishment, or defence of legal rights. In relation to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw your consent to Our processing of Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals in connection with the processing of Personal Data within the European Union. The laws of the European Union and Member States may restrict your rights in relation to Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and number of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.

13.11 Where it does not conflict with the provisions of section 13 of the law, the information you request under your section 13 rights will be provided free of charge. Where a request is unfounded or excessive, in particular because it is repetitive, 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 doubts about the identity of the person who submitted your request, we may ask them to provide reasonable means of verifying their identity.