Privacy Policy

1. The Scope

This policy explains what Personal Data the Company collects from natural individuals, and how that data is processed, shared with third parties, and secured.

This Policy covers 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 aged 18 and over. We do not knowingly collect information from anyone under 18, nor do we permit minors to use our services. If we become aware that we hold data belonging 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 request specific personal data from you.

2.2 We also 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is non-personal 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 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 described in this section, in accordance with the applicable legal basis.

For more information about the processing carried out to protect legitimate interests, contact us by email.

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

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 data.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data you have submitted to us directly to those platforms. Your Personal Data may be shared with multiple third-party trading platforms, and its use will be governed by their respective privacy policies.

6.3 The Company may share Personal Data with related entities or business partners to support the enhancement and improvement of the products and services provided to its 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 or buyers, or with lenders to the Company or any other group company, in connection with a transaction such as a transfer or sale of company assets, or as part of 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 when 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 most relevant to you. Cookies are also used for statistical and analytics purposes.

7.3 Some cookies used on this Website 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 the browser is closed and are used to recognise you as a returning user and facilitate access to the Website.

7.5 Please note that disabling certain functions may cause some or all Website features to behave unexpectedly.

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

8. Retention of Personal Data

The Company will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or binding orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you agree, we will continue sharing your data 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 organizations. The Company takes all necessary steps to protect your personal data and to ensure that you retain the right to assert your rights and access effective legal recourse.

9.3 The Company 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@sternvaultwick.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational 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 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 In certain circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or secure your Personal Data.

10.4 Transmitting Personal Data over the internet carries inherent security risks. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

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 actions taken through them.

11.2 When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Exercise caution when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. Any changes will be communicated 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 any Personal Data we no longer require. You may also restrict the scope or type of processing applied to your personal information.

If you are an EEA resident, please refer to this page for details on the rights available to you regarding your Personal Data. To exercise any of these rights, submit your request by email to the address below.

13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. This right to access must not conflict with the rights and freedoms of others. Where complying with a request would be detrimental to the rights or freedoms of a third party, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You may also 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 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 no alternative legal basis for processing exists; (c) you object, on grounds relating to your particular situation, to processing of your Personal Data carried out on the basis of legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) erasure is required to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by 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 natural person, 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 a contract to which you are a party, you have the right to receive your Personal Data 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 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 are able to 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 process your Personal Data notwithstanding your objection. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for such purposes.

13.9 Right to Withdraw Consent You may withdraw your consent for Us processing your Personal Data 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 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 the rights described in this section 13 as they apply to your Personal Data.

We will respond to requests made under the rights set out in 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. You will be notified of any extension, along with the reasons for it, within one month of your request.

Subject to section 13 of the law, information requested under your rights pursuant to that section will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of fulfilling the request or notifying you of the action taken. We may also decline to act on the request.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide adequate means of verification.