Privacy Policy

1. The Scope

This policy outlines the types of personal data the Company collects from individuals and how it processes, shares, and protects that information.

This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified, or identified through a combination of additional information we hold or can access.

The Policy defines "processing" as any activity involving the use or collection of Personal Data, including its management, organisation, and storage.

Our services are intended for general audiences and are not designed for anyone under 18 years old. We do not knowingly collect information from anyone younger than 18, nor do we allow such persons to use our services. If we discover that a child has provided information to us, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

When you access our service, channels, or website, we collect your Personal Data. In some cases, we may also ask you to provide it directly.

In other cases, we collect your Personal Data by analysing how you use our Services and service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

You aren't obliged to provide us with any personal data. However, in certain circumstances, if you don't supply us with necessary personal data, we may not be able to offer our services or allow you to access the website.

4. What Personal Data We Collect

The information you collect is not personal information and cannot be used to identify you.

Personal data you provide to us voluntarily when you connect to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading: this 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 outlined in this section, in accordance with the applicable legal basis.

For more details on how we process your information to protect legitimate interests, please contact us via email.

5.4 Below are the reasons and legal grounds on which we may use the information you provide:

6. Transfer of Personal Data to Third Party

The Company may also share your Personal Data with third-party service providers — such as hosting and storage providers — for purposes including IP address information and user experience analysis.

You can also request that we share your specific Personal Data with third-party trading platforms. We'll provide the Personal Data you've given us to these platforms, whose use of it is governed by their own privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.

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

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

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

7. Cookies and Services from Third Parties

We may use third-party services, such as advertising and analytics providers, on our website. These companies may also use cookies or similar technologies.

7.2 Cookies are small text files stored on your device when you visit our website. We use them to understand your preferences and browsing behaviour, improve your experience, remember your settings, and personalise the products and services we offer. Cookies also help us gather statistics and analytics.

7.3 Some cookies we use are session cookies. These are temporary files downloaded to your device that expire when you close your browser. We also use persistent cookies, which remain on your device after you close your browser. Persistent cookies help us recognise you as a returning user and allow you to return to the website more easily.

7.5 However, be aware that certain Website 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

We'll keep your personal data for as long as necessary to fulfil the purposes outlined in this Policy, or for longer periods if required by law, regulation, or applicable court orders.

We'll share your information with third-party trading platforms for 12 months. If you agree, we'll continue sharing your data for a further 12 months.

We regularly review the Personal Data we hold to ensure it's no longer necessary for its original purpose.

9. International Transfers

Your personal information may be transferred to other countries (that is, your personal data may be sent to a third country or to international organisations). The Company takes all necessary steps to protect your Personal Data and ensure that data users can exercise their rights and access effective legal remedies.

The Company can provide details about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. Contact us at: support@fernly-vaultmere.com

10. Security of Personal Data

We've implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your Personal Data will remain secure at all times. We are not liable for any indirect, incidental, or consequential losses arising from the use or disclosure of your Personal Data, including (but not limited to) losses from transmission errors, unauthorised third-party access, or other circumstances beyond our control.

In the event of legal obligations or circumstances beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot be responsible for how these third parties protect your Personal Data once it's been shared.

Personal data cannot be transferred over the web with complete safety. We cannot guarantee the security of personal data you send to us through the internet.

11. Hyperlinks to Third Party Websites

We provide links to third-party websites and applications on our site. These external services aren't under our control, and we're not responsible for how they collect or handle your personal data. Our privacy policy doesn't apply to activity on those third-party sites or apps.

When visiting any third-party websites or apps, we recommend you read their privacy policies before deciding to access or use them. We also suggest you carefully consider what Personal Data you share with them.

12. Modifications to This Policy

This Policy may be updated at any time. If we make changes, we'll notify you by posting the updated Policy on our website.

12.2 Additionally, when we make significant changes to this Policy, we'll notify you through appropriate channels and publish an announcement on our website.

Any amendments, unless explicitly stated otherwise, will take effect following publication of the revised Policy.

13. Your Rights

You're entitled to request that we verify the accuracy of Personal Data collected about you, correct any errors, and delete Personal Data we no longer need. You may also restrict how we process your personal information.

If you're an EEA resident, please refer to this page for your data rights. You can exercise these rights regarding your Personal Data by emailing the address below.

13.3 Access rights The Company can verify the accuracy of your Personal Data and confirm what information is being processed. If your data is being processed, you have the right to access it. The Company will provide an electronic copy of your Personal Data at no cost, though a reasonable fee may apply for additional copies. Data will be made available electronically upon request. Your right to access Personal Data cannot override the rights and freedoms of others. If honouring your request would harm another person's rights or freedoms, the Company may refuse the request or limit how it can fulfil it.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete or inaccurate Personal Data about you be corrected, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons allow you to request erasure of your Personal Data: (a) the data is no longer needed for the purpose it was collected for; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time to processing based on legitimate interests pursued by us or a third party, for reasons specific to your situation; (d) the Personal Data has been processed unlawfully; or (e) the data must be deleted to comply with a legal obligation. This right does not apply if processing is necessary (a) to fulfil an obligation required by European Union law or Member State law; or (b) to establish, exercise or defend legal claims.

13.6 Processing restrictions If you're concerned about the accuracy of your Personal Data, you can ask the Company to limit how your Personal Data is processed. If you request this restriction, your Personal Data may only be retained if you've given consent, or where it's needed to establish, exercise, or defend legal rights—either your own or those of another individual—or where there's a substantial public interest within the European Union or a Member State.

13.7 Right to data portability If the processing is carried out by an automated system and is based on your consent or a contract you're part of, you have the legal right to review your Personal Data provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your right to erasure is not affected by exercising your right to data portability. The right to data portability does not override the rights or freedoms of anyone else.

13.8 Right to challenge You have the right to object to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party, at any time. This right extends beyond profiling based solely on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may only continue if you can show that our interests are outweighed by your rights, freedoms, or interests, or by the exercise, establishment, or defence of legal rights. Regarding direct marketing, you have the right to object to the processing of your Personal Data at any time.

13.9 Right to withdraw consent You may withdraw your consent for us to process your Personal Data at any time. This will not affect the lawfulness of any processing that relied on your consent before you withdrew it. You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by an EU member state to protect the fundamental rights of individuals regarding Personal Data processing within the European Union. EU and member state laws may limit your rights concerning your Personal Data, as set out in this section 13.

13.10 We'll provide you with the information you've requested under the rights outlined in section 13 of this agreement within one month of receiving your request. If needed, we may extend this timeframe to up to two months, depending on the nature and volume of your request. We'll notify you of any extension and the reasons for it within one month of receiving your request.

As long as it does not conflict with section 13 of the law, information you request under your rights in section 13 will be provided at no cost. If your request is unjustified or excessive, or if you make repeated requests, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the action you've requested. We may also decline to proceed.

If we have concerns about whether you're the person who made the request, we may ask you to provide reasonable proof of your identity.