Privacy Policy

We are committed to being transparent about how we collect and process your personal information.

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods to keep you informed about how your Personal Data is handled.
Where specific details are relevant to you, we will provide them at the appropriate time.
We welcome any questions you may have and will clarify any limitations imposed by law. You can reach us by email at: info@boldstewardimony.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for several purposes: to provide the website and connect you to third-party trading platforms (the "Services"); to improve the site and protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities related to the Services.
We also process your personal data to better understand your preferences and needs.

Use the tools available to protect your rights in relation to your Personal Data:

To exercise your rights over your personal data, contact us at any time. You may request that we update or delete your personal data, restrict or stop its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request accordingly.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your personal data, we are committed to employing a range of methods and measures to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of personal data the Company collects about natural persons, and how that data is processed, shared with third parties, and secured.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be recognised directly or through a combination of information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for users aged 18 and above. We do not knowingly collect personal data from anyone under 18, and we do not permit such persons to use our services. If we become aware that personal data belonging to a minor has been collected, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, service channels, or website, we collect personal data. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our services or by receiving your information from our third-party partners.

You are not required to provide personal information to the company. However, choosing not to do so may prevent us from delivering our Services or granting you access to the website.

Providing personal data is optional. However, if you choose not to share certain information, we may be unable to deliver our Services or grant you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information about your online activity log, traffic data (such as IP address, access dates and times), language settings, software crash logs, browser type, and device details. This information is non-personal and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: Service Providers: We work with trusted third-party service providers who assist in operating our platform and delivering our services. These providers are granted access to your personal data only to the extent necessary to perform their functions and are bound by confidentiality obligations. Legal and Regulatory Requirements: We may disclose your personal data to regulatory authorities, law enforcement agencies, or other government bodies where required by applicable law or where we have a good-faith belief that disclosure is necessary to comply with a legal obligation, protect our rights, or prevent harm. Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We will notify you of any such transfer where required by law. Third-Party Partners: Where you have consented or where we have a legitimate interest, we may share your personal data with selected third-party partners for purposes consistent with this Policy. We do not sell your personal data to third parties. Any transfer of personal data is conducted in accordance with applicable data protection requirements and subject to appropriate safeguards to protect your information.

We may also share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis. At your request, we may transfer specific Personal Data to third-party trading platforms. In such cases, your Personal Data will be shared directly with those platforms, and its use will be governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform. We may share Personal Data with affiliated entities or business partners where this supports the development and improvement of our products and services. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities. We may also share your Personal Data with prospective investors, acquirers, or lenders — whether in connection with the Company or any entity within its group — in the event of a sale or transfer of assets, merger, restructuring, consolidation, or insolvency involving the Company or any group entity.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. Some of these services may collect and process your personal data for their own purposes. By continuing to use our website, you acknowledge and accept this. Third-party service providers operate under their own privacy policies, which govern how they handle your data. We recommend reviewing those policies directly. We are not responsible for the data practices of third parties. You can manage or disable cookies through your browser settings at any time. However, disabling certain cookies may affect the functionality of our website or prevent you from accessing some features.

We may work with third parties — such as advertisers and analytics providers — who operate on our website and may also use cookies or similar technologies. 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 content and services to you. Cookies are also used for statistical and analytics purposes. We use two types of cookies. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and help the website recognise you as a returning user, making it easier to resume your experience.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We 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, regulations, or orders.
We share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue sharing your data for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

Transfers of Personal Information to a Third-Party Country or International Organisation We may transfer your personal data to recipients located outside your country of residence, including in third-party countries or through international organisations. Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal data in accordance with applicable data protection requirements. These safeguards may include, but are not limited to, standard contractual clauses, adequacy decisions, or other legally recognised transfer mechanisms. By using our services, you acknowledge that your personal data may be transferred, stored, and processed in jurisdictions that may have different data protection standards than those in your country. We take reasonable steps to ensure that any third party receiving your personal data is bound by obligations that provide a level of protection consistent with our own data protection practices.

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures are designed to ensure a level of security appropriate to the risks involved in processing your personal data. Access to your personal data is restricted to personnel and third parties who require it to perform their functions. All such parties are bound by confidentiality obligations. While we take reasonable steps to safeguard your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we will notify you and any applicable authority of a breach where required. You are responsible for keeping your account credentials confidential. Do not share your password with any third party. If you believe your account has been compromised, contact us immediately.

We have implemented appropriate organizational and technical measures to protect personal data, including against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that personal data will be maintained with complete security at all times. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data, including disclosures resulting from transmission errors, unauthorized third-party access, or other causes beyond our control.
Where required by legal or regulatory obligations outside our control, we may be required to disclose personal data to third parties, including public authorities. We cannot control the security measures applied to your personal data by such third parties in those circumstances.
Transmission of personal data over the internet cannot be fully secured. We cannot guarantee the security of personal data you transmit to us online.

11. Links to Third-Party Websites

This website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through such sites or applications.
Before accessing or using any third-party site or application, we recommend reviewing their privacy policy. We also advise caution when providing Personal Data to any third party.

12. Modifications to this Policy We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, communicated to you directly. Your continued use of our services after any modifications constitutes your acceptance of the updated Policy. We recommend reviewing this page periodically to stay informed of any changes.

Before visiting any third-party website or app, read their privacy policy carefully. Only share your personal data with them once you are comfortable with how it will be used.

13. Your Rights Regarding Your Personal Information You have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us using the details provided in this policy. Right of Access You have the right to request a copy of the personal data we hold about you, along with information on how we process it. Right to Rectification If any personal data we hold is inaccurate or incomplete, you have the right to request that we correct or complete it. Right to Erasure In certain circumstances, you have the right to request that we delete your personal data. This right is subject to legal or regulatory obligations that may require us to retain certain information. Right to Restrict Processing You have the right to request that we limit how we process your personal data in specific situations, such as while we verify the accuracy of the data or assess an objection you have raised. Right to Data Portability Where processing is based on your consent or a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format, or to have it transferred directly to another controller where technically feasible. Right to Object You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms. Right to Withdraw Consent Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. How to Exercise Your Rights Submit your request in writing to our contact address. We will respond within the timeframe required under applicable law. We may request proof of identity before processing your request.

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer need. You may also restrict the scope or type of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please send a written request to the email address below.
Access rights
The Company can verify whether your Personal Data is being processed. If it is, you may request access to that data.
The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response.
Right to rectification
You have the right to have inaccurate Personal Data corrected. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is processed.
Right to erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be deleted to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.
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 party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used format.
You may request that your Personal Data be transferred directly to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure, and must not adversely affect the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those interests. Where you object, the Company will cease processing unless it can demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or where processing is necessary to establish, exercise, or defend legal claims.
You have the right to object at any time to the processing of Personal Data concerning you for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to that withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals' fundamental rights 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 relate to your Personal Data.
We will respond to requests made under section 13 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. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Unless otherwise provided under section 13, information provided in response to your rights will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person submitting a request, the Company may ask for additional information to confirm identity before proceeding.