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 referred to as "We", "Us" or "Our") are committed to safeguarding your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Candor Ledgivance (the "Website").
We want you to make informed choices about the use and processing of Personal Data. We use different methods and procedures to provide you with relevant information. If we believe you need specific details, we will provide them at the appropriate date and time. We are happy to answer any questions you may have about any limitations imposed by law.
1. The Scope
1.1 This policy describes the types of Personal Data the Company collects about natural individuals and how it processes, shares with third parties, secures, and otherwise handles that data.
1.2 This Policy concerns information related 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 have or can access.
1.3 The Policy defines "processing" as a process that requires using or gathering Personal Data. This includes managing, structuring, and storing 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 anyone under 18 years old. We do not knowingly permit such persons to use our services. If we become aware of any information about children, we will erase it as quickly 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. We may request your Personal Data in certain instances.
2.2 In other instances, we gather your Personal Data by analysing your use of our Services or our service channels, 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. However, in certain circumstances, failure to provide Us with Personal Data may hinder Us from offering the Services or hinder users from accessing the website.
4. What Personal Data We Collect
4.1 This includes information from your online activity log and traffic data, 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 private information and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you voluntarily provide to Us 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 trade: this information includes your complete name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 The company processes your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.
5.2 Without a legal basis, the Company cannot use Personal Data concerning you. The legal grounds on which the Company can process Personal Data concerning you are:
- You have consented to the processing of your Personal Data for one or more reasons. 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 need to carry out processing to meet their legitimate interest. For example, this may be necessary to improve Our Services or defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact Us by email for more details about the processing necessary to safeguard the legitimate interests.
5.4 Below is a list of reasons and legal grounds for which we may use the information you provide to us:
Scope
Legal Basis
1. To provide your personal information to third-party companies at your request to gain access to digital trading
If you request it, we may ask you for Personal Data to forward to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is necessary to respond to your questions regarding the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed to meet any legal obligation or administrative, judicial, or legal requirements that apply.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services: We may use Personal
Data 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 the interests of a third party.
6. To perform and manage actions aligned with the requirements of Our Services
These 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 different issues, we use various analytical techniques, including statistical methods.
Processing is necessary for the legitimate interests of the Company or a third party.
8. To safeguard our assets, rights and interests, and those of third parties
We may process Personal Data 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 can also provide Personal Data to third-party companies that offer services to us, such as hosting and storage providers, IP address information, and analysis of user experiences.
6.2 You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you provide to Us to third-party trading platforms. Their 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. This may provide the Company with the resources needed to enhance and improve the products and services it provides to its customers.
6.4 Where necessary 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, if the same 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 companies that provide advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.
7.2 Cookies are small text files placed on your device whenever you visit or access the website. They collect information about your preferences and browsing habits to improve the user experience, remember your preferences, and customize products and services you may enjoy. Cookies are also used for statistics and analytics.
7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website identify you as a returning user and allow users to return to the website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary for you to access the features you have requested and navigate our website. Cookies are used to provide the information, products and services you have requested.
They are required for your device to download and stream data. They allow you to move around the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are erased when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and save your preferences.
Additional Information
They remain until their expiry date and are stored even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and help improve it. They also allow Us to analyse our website.
Additional Information
Cookies store anonymous data that is not associated with any identified or identifiable natural person. Some are removed when you close your browser. Other cookies remain valid indefinitely.
7.4 Cookies can be blocked or removed. To prevent or remove cookies, adjust your browser settings. Below are links to help you with this process for several commonly used 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 operate as expected if this happens.
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 necessary to fulfill the purpose of processing Personal Data, as described in this Policy, or for longer periods as permitted by law, regulations, policies, and applicable orders.
8.2 We will share your information with third-party trading platforms for 12 months. If you agree to this, we will continue to share your data for another 12 months.
8.3 We regularly review Personal Data that we have kept 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 international organizations). Company takes all necessary steps to safeguard the Personal Data you provide and ensure that data users can 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 security for Personal Data transferred to it in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
- The transfer was carried out in compliance with the common data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide information on the security measures it uses to safeguard your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@candorledgivance.com
10. Security of Personal Data
10.1 We have taken appropriate organisational and technical precautions to safeguard Personal Data, including preventing accidental or illegal destruction, loss, or modification of Personal Data.
10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We are not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosure of Personal Data due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
10.3 If legal obligations or other obligations beyond our control apply, we may be required to provide Personal Data concerning you to third parties, such as public authorities. In these situations, we cannot control how third parties protect your Personal Data.
10.4 Personal Data cannot be transferred over the web in a completely secure manner. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to Third Party Websites
11.1 The website provides links to third-party sites and applications. These sites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these sites or applications. This Policy does not apply to actions taken through such sites or applications.
11.2 When you visit any third-party websites or apps, We recommend that you read their privacy policies before deciding whether 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 may change at any time. If we change this Policy, we will notify you by posting the updated Policy on our website.
12.2 In addition, when we make significant modifications to this Policy, we will attempt to inform you using the methods we believe are appropriate and will publish an announcement on our website.
12.3 Unless explicitly specified, any amendments will become effective after the revised Policy is published.
13. Your Rights
13.1 You are entitled to request that we verify the accuracy of Personal Data collected about you, rectify any mistakes, and 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 are available to you regarding the information you provide in relation to your Personal Data. You may request to exercise your rights by emailing the address below.
13.3 Access rights The Company may verify the accuracy of the Personal Data being processed about you. If such Personal Data is being processed, you may access it. The Company will provide 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 adversely affects another person's rights and freedoms, the Company may refuse to comply with the request or limit the extent to which it fulfils it.
13.4 Right to rectification The Company has the right to rectify inaccurate Personal Data. You have the right to demand rectification of any insufficient Personal Data concerning you, taking into account the reason for processing.
13.5 Right to Erasure The following reasons apply: (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 other legal basis for processing; (c) You object at any time, for reasons specific to your situation, to the processing of Personal Data about You based on legitimate interests pursued by Us or by a third party; (e) Personal Data are processed unlawfully; or (f) Personal Data must be erased to comply with the company's legal obligation. This right does not apply where processing is necessary (a) to fulfill a legal obligation requiring processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data. If you request a restriction, Personal Data may only be kept with your consent, to create, exercise, or defend legal rights, to defend the rights of another natural individual, 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 automated means and is based on your consent or on a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You may 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 must not adversely affect the rights or freedoms of others.
13.8 Right to challenge You have the right to oppose, at any time, any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third-party. This includes profiling based solely on those legitimate interests. If we can establish compelling legitimate grounds for processing Personal Data, we may continue processing unless you prove that your rights, freedoms, or interests, or the exercise, establishment, or defense of legal rights, override those grounds. For 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 to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing that relied on your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may lodge an appeal with a supervisory authority established by a Member State to safeguard individuals’ fundamental rights 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 the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This time frame may be extended to up to two months, if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
13.11 Provided 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 not justified or excessive, particularly if repeated, we may charge a reasonable amount to cover the administrative expenses of providing the information or communicating the requested action. We may also decline to act.
13.12 If we have doubts about the identity of the real person who submitted your request, we may ask the person making the request to provide reasonable means of identifying themselves.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Candor Ledgivance 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@candorledgivance.com