Privacy Policy

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects from natural persons, and how that data is processed, shared with third parties, secured, and otherwise handled.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or by combining additional information we hold or can access.

1.3 Under this Policy, "processing" means any operation that uses or collects Personal Data, including its management, structuring, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such persons to use our services. If we learn that we hold information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access our services and channels or visit our website. In certain instances, we may request your Personal Data directly.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving 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. In certain circumstances, however, withholding such data may prevent Us from delivering Our Services or granting you access to the website.

4. What Personal Data We Collect

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

4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade, including your full 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, in accordance with the applicable legal basis.

5.3 Contact us by email for more details about the processing necessary to protect legitimate interests.

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

6.1 The Company may also share Personal Data with third-party providers who deliver services to us, such as hosting and storage providers, IP address information, and analysis of user experiences.

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 given to us to those third-party trading platforms. Their use of your Personal Data is governed by their own 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 provides the resources needed to enhance and improve the products and services it offers its customers.

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

6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, where such a 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 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or similar technology.

7.2 Cookies are small text files stored 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 that may interest you. Cookies are also used for statistics and analytics.

7.3 Some cookies we use are session cookies. These are temporarily stored on your device and last only until you close your browser. Other cookies are persistent and remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and allow you to navigate back to the website.

7.5 However, if this occurs, please be aware that some or all of the Website's functions and features may not work as you expect.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your personal data with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to third countries or international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 You may request details about the security measures we use to protect your Personal Data when it is transferred to third-party countries or international organisations. Email us at: support@fulcrum-vestwick.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also 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, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Legal or other obligations beyond our control may require us to disclose your Personal Data to third parties, such as public authorities. In these situations, we cannot control the level of security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you transmit to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that the Company does not supervise. 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 them.

11.2 Before you access or use any third-party website or app, We recommend reviewing their privacy policies and exercising caution when providing any Personal Data to them.

12. Modifications to This Policy

12.1 We may update this Policy at any time. If we make changes, We will notify you by posting the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will notify you through methods we consider appropriate and publish an announcement on our website.

12.3 Unless otherwise specified, any amendments take effect once the revised Policy is published.

13. Your Rights

13.1 You may 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 restrict the scope and types of processing applied to your Personal Data.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, you have the right to access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Where you request it, the data will be provided electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with the request or limit the extent to which it does so.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of 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 legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet the company's legal obligation. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Restricting processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect 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 Where processing is automated and based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company. You may also request that your Personal Data be transmitted 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 and freedoms of others.

13.8 Right to object You have the right to object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can show that your rights, freedoms, or interests override those grounds, or where the processing relates to the exercise, establishment, or defence of legal rights. You also have the right to object at any time to the processing of Personal Data concerning you for direct marketing purposes.

13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may file a complaint with 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. The laws of the European Union and Member States may limit your rights concerning Personal Data about you, as set out in this section 13.

13.10 We will provide the information you request under your rights in Section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and number of requests. We will notify you of any such extension, along with the reasons, within one month of receiving your request.

13.11 Provided it does not conflict with Section 13 of the law, the information you request under your rights in Section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or acting on the request. We may also decline to act.

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