Privacy Policy

1. The Scope

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

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 For the purposes of this Policy, "processing" means any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences. We do not permit use by anyone under the age of 18, and we do not knowingly collect information from minors. If we become aware that we have inadvertently collected such information, 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 also request personal data directly 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

3.1 You are not required to provide Us with any Personal Data. However, in certain circumstances, withholding Personal Data may prevent Us from delivering the Services or prevent you from accessing 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 voluntarily provide to us when connecting to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade 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 on the processing used 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

The Company may also share Personal Data with third-party service providers, including hosting and storage providers, IP address data processors, and user experience analytics platforms.

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 will then be subject to the privacy policies of the respective third-party trading platforms. Please note that your Personal Data may be shared with more than one such platform.

6.3 The Company may share Personal Data with related entities or business partners to enhance and improve the products and services provided to its customers.

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

We may share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of assets, a merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party service providers — such as advertisers and analytics companies — 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 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 most relevant to you. Cookies are also used for statistics and analytics purposes.

Some cookies we use 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 your browser is closed. Persistent cookies help the Website recognise you as a returning user and allow you to resume access to the website.

7.5 Please note that disabling cookies may cause certain features or functions of the Website to behave unexpectedly or not work at all.

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

8. Retention of Personal Data

We 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 orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

We periodically review the Personal Data we hold to determine whether it is still 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 the personal data you provide, ensuring 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@sturdyreckontance.com

10. Security of Personal Data

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 protected from all errors or breaches. 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, unauthorised third-party access, or other causes beyond our control.

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 protect 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

11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how these sites or applications collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

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

This Policy may be updated at any time. Any changes will be reflected in the updated Policy posted on our website.

12.2 When significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless explicitly stated otherwise, 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 Personal Data we no longer require. You may also restrict the scope or types of processing applied to your personal data.

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

13.3 Access rights You have the right to verify that your Personal Data is being processed accurately and, where it is, to access that data. 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 a request is detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request correction of incomplete Personal Data concerning you, taking into account 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 legal basis for processing exists; (c) you object, on grounds specific to your situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to fulfill an obligation required under 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 in place, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, 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 that you have provided to the Company in a structured, commonly used format. You may also 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. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right at any time to object 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 defense of legal claims, we may continue such processing 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 Refuse Consent You may withdraw your consent for Us processing 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 also appeal to 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. EU and member state law may limit your rights in relation to your Personal Data, as set out in this section 13.

We will respond to your request under 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 or volume of requests. You will be notified of any extension, along with the reasons, within one month of your original request.

Subject to section 13 of the law, information requested under your section 13 rights 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. We may also decline to act on such requests.

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