Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects on natural individuals, how it processes and shares that data with third parties, how it secures those processes, and related matters.

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 process involving the use or collection of Personal Data. It includes the management, organisation, and storage of Personal Data.

1.4 Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from any person younger than 18 years old. We do not knowingly permit such persons to use our services. If we become aware that we hold information about a child, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect Personal Data. We may also request your Personal Data in certain instances.

2.2 In other instances, we collect your Personal Data by analysing how our Services or service channels are used, or by receiving your information 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, you may not be required to supply Us with any Personal Data. This could hinder Us from offering the Services or hinder users from accessing the website.

4. What Personal Data We Collect

4.2 The information collected is not private and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you provide to Us at your own choice when you connect with an online trading platform of a third party through Us.

4.4 Personal information you provide specifically to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 Your Personal Data is processed by the company for the purposes described in this section, in accordance with the applicable legal basis.

5.3 Contact us via email for more details about the processing required to protect legitimate interests.

5.4 Below is a list of 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 companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analytics.

6.2 You can also ask us to share specific Personal Data about you with third-party trading platforms. We will provide the Personal Data you supply to us in these instances to those third-party trading platforms. The use of your Personal Data is subject to 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, providing the Company with the resources needed to enhance and improve the products and services it offers its customers.

6.4 Where there is a need to safeguard the rights of third parties or assets, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in the group of companies in the event that 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 Third-party services, such as advertising providers on our website or analytics companies, may be used. These companies may also make use of cookies or other technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve the user experience, track your preferences, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and remain active for a short period before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They help the Website identify you as a returning user and allow users to return to the website.

7.5 However, please be aware that certain functions and features of the Website, or all of them, 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

8.1 The Company will retain Personal Data about you for as long as is necessary to fulfil the purpose for which it is processed, as described in this Policy, or for longer periods as permitted by applicable law, 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 to this, we will continue to share your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to ensure it is no longer needed.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted 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 are able to assert their rights and access effective legal recourse.

9.3 The Company can provide information about the security measures it employs to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@steadyhoardwarden.com

10. Security of Personal Data

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

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not restricted to, any Personal Data being disclosed due to errors in transmission, unauthorised access by a third party, or any other cause beyond our control.

10.3 In the event of legal or other obligations beyond our control, we may be required to provide Personal Data about you to third parties, such as public authorities. We cannot control the security afforded to your Personal Data by third parties in these situations.

10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.

11.2 When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use their apps. We also suggest that you provide any Personal Data to them.

12. Modifications to This Policy

12.1 This Policy is subject to change at any time. If we change this Policy, we will notify you of the changes by posting the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will attempt to notify you using the methods we consider appropriate and will publish an announcement on our website.

12.3 Unless explicitly specified otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your Rights

13.1 You are entitled to request us to verify the accuracy of Personal Data being collected about you, to rectify any mistakes, and to delete all Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to you with respect to the information you provide in relation to your Personal Data. You may request to exercise these rights by writing an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If it is, you are able to access your Personal Data. The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights or freedoms of another person, the Company may refuse to comply with the request or limit its capacity to fulfil it.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You are entitled to demand that any incomplete Personal Data concerning you be rectified, taking into account the reason for processing.

13.5 Right to Erasure The following reasons are applicable: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to process; (c) You object at any time, based on a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are unlawfully processed or (f) Personal Data must be removed to meet the lawful obligation of the company. This right is not applicable in the event the processing is necessary (a) to fulfil an obligation imposed by law that is required to be processed under European Union law or Member State law; or (b) to create, exercise or defend legal rights.

13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data. If you ask that Personal Data be restricted, Personal Data may only be kept if you give consent, or in order to create, exercise or defend legal rights, or to defend the rights of another natural individual, or in the case of a reason that is of significant public interest within the European Union or a Member State.

13.7 Right to data portability If the process is carried out by an automated system and is based on consent or a contract you are party to, you have the legal right to access and review your Personal Data that you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. The rights you hold under the right to erasure are not affected by the exercising of your right to data portability. The right to data portability does not interfere with the rights or liberties of any other person.

13.8 Right to challenge You have the right to oppose any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, at any time. This right is not limited to profiling based solely on those legitimate interests. If we are able to establish compelling legitimate grounds for processing Personal Data, we will not be able to continue doing so unless you can prove that they outweigh your rights, freedoms, or interests, or the exercise, establishment or defence of legal rights. Concerning direct marketing, you have the right at any time to oppose the processing of Personal Data concerning you.

13.9 Right to refuse consent You may revoke your consent for Us processing Personal Data about you at any time. This will not alter the legality and lawfulness of any processing that was dependent upon your consent prior to the revocation. You are entitled to lodge a complaint with the authority that supervises you. You may lodge an appeal to a supervisory authority established by a member state to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and Member States could limit your rights in relation to Personal Data concerning you, as detailed in this section 13.

13.10 We will provide you with the requested information in accordance with the rights set out in section 13 of this agreement within one month of receiving your request. The time frame may be extended by up to two months if necessary, depending on the nature and volume of requests. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

13.11 As long as it is not contrary to the provisions of section 13 of the law, the information you request pursuant to your rights under section 13 will be made available free of cost. If the request is unjustified or excessive, particularly where requests are repeated, We may charge a reasonable amount to cover the administrative expenses of providing the information or notifying you of the action requested. We may also not act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask that person to provide reasonable means of identifying themselves.