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 (also known as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy explains how we collect and store the information you provide through the website Vorn Ledstead (the "Website").
We want you to be fully informed about how your personal data is used and processed. We use various methods to provide you with relevant information. When we believe specific details are necessary, we'll share them with you at the right time. We're happy to answer any questions you may have, within the limits of applicable law.
1. The Scope
1.1 This policy outlines the types of Personal Data the Company collects from individuals and explains how it processes, shares with third parties, secures, and manages that information.
1.2 This Policy applies to 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 can access.
1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data. This includes managing, organizing, and storing Personal Data.
1.4 Our services are intended for general audiences and are not designed for use by anyone under 18 years of age. We do not knowingly collect or solicit information from any person under 18. We do not knowingly permit such individuals to use our services. If we become aware of any information collected from children, we will delete it as promptly as possible.
2. What Personal Data Do We Have on You
2.1 When you access the service and channels or visit our website, we collect Personal Data. In certain cases, 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 your information from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You are not required to provide Us with any personal Data. However, in certain circumstances, if you choose not to supply Us with Personal Data, this may prevent Us from offering the Services or restrict your access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and data about your traffic, 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
4.2 The information you collect is not personal data 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 discretion when you connect with a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party platforms to enable trading: this 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 outlined in this section and in accordance with the applicable legal basis.
5.2 Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company is able to process your Personal Data are:
- You have provided consent for the processing of your personal data for one or more specific purposes. This applies when you submit personal information through the Website so we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to meet their legitimate interests. For example, this is necessary to improve Our Services or defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact us via email for more details about the processing required to protect our legitimate interests.
5.4 Below is a list of reasons and legal grounds on which we may use the information you provide us with:
Scope
Legal Basis
1. To share your personal information with third parties at your request in order to access digital trading
If you request it, we may collect Personal Data from you to forward to third-party companies.
You have provided consent for your personal data to be processed for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data is necessary to help us answer any queries you may have regarding the Services.
Processing is necessary to protect the legitimate interests of the Company or a third party.
3. To meet any legal obligation or comply with administrative, judicial, or regulatory requirements, Personal Data is processed as necessary to fulfill legal obligations.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services Personal
Data may be used by us to enhance Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. To perform and manage actions that align with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
To make decisions on various matters, we use different analytical techniques (including statistical ones).
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
8. To safeguard our assets, rights and interests as well as those of third parties
Personal Data may be processed by us in order to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
Processing is necessary for 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 companies, IP address information providers, and user experience analysts.
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 Personal Data you have supplied to us to those third-party platforms. The use of your Personal Data by these platforms is governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
6.3 The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources necessary to enhance and improve the products and services it offers to its customers.
6.4 In the event it becomes necessary to protect 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 your Personal Data with potential investors, buyers, or lenders to the Company or any group company if such a transaction occurs (including the transfer or sale of assets belonging to the Company or any group company), 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 or analytics companies, may be used on our website. These companies may also use cookies or similar technologies.
7.2 Cookies are small text files stored on your device whenever you visit or access the website. They collect information about your preferences and browsing behaviour to enhance user experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical analysis and analytics purposes.
7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and remain active only until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after you close your browser. They help the Website recognize you as a returning user and make it easier for you to access the site again.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for accessing the features you've requested and for navigating our website. They enable us to deliver the information, products, and services you've asked for.
They allow your device to download and stream data, letting you move around the site, use its features, and return to pages you've visited before.
Additional Information
Cookies gather Personal Data, including your username and most recent login date, to verify that you're logged in to the website. They're deleted automatically when you close your browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognise you on each visit to our site and remember your settings and preferences.
Additional Information
They remain active 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 on site performance and to help improve it. They also allow us to conduct analysis on our website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable individual. They can be deleted when you close your browser. Other cookies remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, you need to adjust your browser's settings. Below are links to help you with the process for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, be aware that some or all of the Website's functions and features 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 your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer periods as permitted by law, regulations, policies, and applicable orders.
8.2 We'll 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 another 12 months.
8.3 We regularly review the Personal Data we retain to ensure it is no longer required.
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 ensure that data users have the ability to assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and Council of 27 April 2016 (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Send an email to: support@vorn-ledstead.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational and technical measures to protect Personal Data. This includes preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee that your Personal Data will remain secure 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, any disclosure resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.
10.3 If we are required by law or other obligations beyond our control, we may need to share your Personal Data with third parties, such as government authorities. We cannot control how these third parties protect your Personal Data in such circumstances.
10.4 Personal Data cannot be transferred over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us online.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications. These applications and websites are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to activities conducted through such sites or apps.
11.2 When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use their services. We also suggest reviewing them carefully before providing any Personal Data.
12. Modifications to This Policy
12.1 This Policy may be updated at any time. If we make changes to this Policy, we will notify you by posting the revised version on our website.
12.2 In addition, when we make significant changes to this Policy, we will make reasonable efforts to notify you through appropriate channels and will post an announcement on our website.
12.3 Unless explicitly stated otherwise, any amendments will take effect upon publication of the updated Policy.
13. Your Rights
13.1 You are entitled to request that we verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer require. You may also limit the types of processing applied to your personal information.
13.2 If you are a resident of the EEA, please refer to this page. You have the following rights concerning your Personal Data. To exercise these rights, you may submit a request by sending 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 processed, 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 if you request it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfill it.
13.4 Right to rectification The Company has the right to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data relating to you be corrected, taking into account the purpose of processing.
13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed 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 at any time, based on a reason specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are being processed unlawfully; or (f) Personal Data must be deleted to comply with a legal obligation of the company. This right does not apply if the processing is necessary (a) to fulfill a legal obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company limit the processing of your Personal Data. If you request such a restriction, your Personal Data may only be retained with your consent or for the purpose of establishing, exercising, or defending legal rights, protecting the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.
13.7 Right to data portability If processing is carried out by an automated system and is based on your consent or a contract to which you are a party, you have the legal right to receive the Personal Data 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. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data portability does not interfere with the rights or freedoms of others.
13.8 Right to challenge You have the right to object at any time to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data that override your rights, freedoms, or interests—or are necessary for the establishment, exercise, or defense of legal claims—we may continue processing. Regarding direct marketing: You have the right to object at any time to the processing of your Personal Data for such purposes.
13.9 Right to refuse consent You may withdraw your consent for Us to process your Personal Data at any time. This will not affect the legality of any processing that relied on your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may submit an appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. European Union and Member State laws may limit your rights concerning your Personal Data, as outlined in this section 13.
13.10 We will provide you with the requested information in accordance with the rights outlined in section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the complexity of the request and the volume of requests received. If an extension is required, we will notify you within one month of receiving your request and explain the reasons for the delay.
13.11 As long as it does not contradict the provisions of section 13 of the law, the information you request under your rights pursuant to section 13 will be provided free of charge. If your request is unfounded or excessive, particularly if it is repetitive, 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.
13.12 If we have doubts regarding the identity of the actual person who submitted your request, we may ask you to provide reasonable means of identification.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Vorn Ledstead 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@vorn-ledstead.com