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. This page explains the methods and procedures we use to keep you informed. Where specific details are needed, we will provide them at the relevant time. If you have any questions or need clarification on any aspect of our data practices, including any applicable legal limitations, please contact us at: info@ivorycapstead.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 with 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.

To exercise your rights in relation to your Personal Data:

To exercise your rights over your personal data, contact us at any time. You may request access to your personal data, ask us to correct or delete it, restrict or stop its processing, or transfer it to you or a third party. We will act on 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 techniques 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, 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 additional information the Company holds or can 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 over. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data belonging to a person under 18 has been collected, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, 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 and channels, or via information received from our third-party partners.

You are not required to disclose personal information to the company. However, choosing not to do so may limit our ability to deliver our Services or grant you access to the website.

Providing personal data is not required. However, choosing not to share it may prevent us from delivering the Services or limit access to the website.

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

This includes data about your online activity, traffic information (including IP address, access date, and access time), language preference, 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 with 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: - When we engage service providers, contractors, or agents who process personal data on our behalf to support the operation of our services. - When required by law, regulation, or court order, or when disclosure is necessary to protect our rights, property, or the safety of our users. - When you have given explicit consent for your personal data to be shared with a specific third party. - When a business transfer occurs, such as a merger, acquisition, or sale of assets, in which case your personal data may be transferred as part of that transaction. Any third party receiving your personal data is required to handle it in accordance with applicable data protection obligations and our data sharing agreements. We do not sell your personal data to third parties for their own marketing purposes. Where personal data is transferred outside your jurisdiction, we take appropriate measures to ensure it remains protected to the same standard applied within our platform.

We may share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis. You may also request that we share specific Personal Data with third-party trading platforms. Where you make such a request, we will share the Personal Data you have provided to us accordingly. Use of your Personal Data by those platforms is governed by their own 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 doing so supports the enhancement or 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, buyers, or lenders — whether in relation to the Company or any other entity within the group — in connection with a transaction, including the transfer or sale of assets, or any merger, restructuring, consolidation, or insolvency proceedings 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 are essential for the site to function; others help us analyse usage, improve performance, or deliver relevant content. Third-party providers we work with may set their own cookies or collect data when you interact with their services. These providers operate under their own privacy policies, which govern how they handle your data. You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Disabling certain cookies may affect how some features of the website function. By continuing to use our website, you consent to the use of cookies as described in this section.

We may engage third-party service providers, including advertisers and analytics companies, to support our website. These providers may also use cookies or similar tracking 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 the products and services shown 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 when you close your browser. Persistent cookies remain on your device after your browser is closed and allow the website to recognise you as a returning user, making it easier to access the site on future visits.

Types of Cookies:

We may use them according to their intended 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 fulfill the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.
We will share your information with third-party trading platforms for 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

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organisational measures to safeguard it against unauthorised access, loss, misuse, alteration, or destruction. While we implement appropriate security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continually review and update our practices to address emerging threats. Access to your personal data is restricted to authorised personnel, partners, and service providers who require it to carry out their responsibilities. All such parties are bound by confidentiality obligations and are not permitted to use your personal data for any other purpose. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately using the contact details provided in this Policy.

We have taken appropriate organisational and technical measures to protect your personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your personal data will be maintained without error, nor can we accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by legal or other obligations beyond our control, we may be required to disclose your personal data to third parties, including public authorities. We cannot control how such third parties handle or secure your personal data 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 through the internet.

Links to Third-Party Websites

Our website contains links to third-party websites and applications. These sites and apps 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 third-party sites or apps.
Before accessing or using any third-party website or app, we recommend reading their privacy policy carefully and exercising caution before sharing any Personal Data with them.

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, you will be notified directly. Your continued use of our services after any modifications constitutes your acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed of any updates.

Before visiting any third-party website or app, read their privacy policy carefully. Only share personal data with them once you are satisfied with how they handle it.

13. Your rights with respect to your personal information You have specific rights regarding your personal information, depending on applicable law and how we process your data. These rights may include: The right to access the personal information we hold about you and to receive details on how it is used. The right to request correction of any inaccurate or incomplete personal information. The right to request deletion of your personal information, subject to our legal obligations to retain certain data. The right to object to or restrict how we process your personal information in certain circumstances. The right to data portability, where we provide your personal information in a structured, commonly used format so you can transfer it to another service provider. The right to withdraw consent at any time where processing is based on your consent, without affecting the lawfulness of processing carried out before withdrawal. The right to lodge a complaint with the relevant data protection authority if you believe your rights have been violated. To exercise any of these rights, contact us using the details provided in this policy. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing your request. Please note that some rights are not absolute. In certain circumstances, we may be unable to fulfil a request — for example, where doing so would conflict with a legal obligation or adversely affect the rights of others. Where we cannot comply, we will explain why.

You have the right to request that we verify the accuracy of Personal Data we hold about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. 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:
These rights apply to the Personal Data you provide to us. To exercise any of them, please send a written request to the email address below.
Access rights
We can verify whether your Personal Data is being processed and, if so, provide you with access to it.
We will supply an electronic copy of your Personal Data currently being processed. A reasonable fee may be charged 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. If a request would be detrimental to another person's rights or freedoms, we may refuse or limit our response accordingly.
Right to rectification
You have the right to require us to correct inaccurate Personal Data. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose for which it is processed.
Right to Erasure
This right applies where: (a) 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) Personal Data has been unlawfully processed; or (f) Personal Data must be erased 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 rights.
Processing restrictions
If you question the accuracy of your Personal Data, you may request that we restrict its processing while accuracy is verified.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal rights, for the protection of another person's rights, 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 a party, you have the right to receive your Personal Data in a structured, machine-readable format.
You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure, and it must not adversely affect the rights and 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 us or a third party, including profiling based on those interests. Where you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or where processing is necessary for the establishment, exercise, or defense of legal rights.
Regarding direct marketing: you have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.
You have the right to 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.
The laws of the European Union and Member States 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, and the reasons for it, within one month of receiving your request.
Unless otherwise provided under section 13, information provided in response to your rights under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, particularly where requests are repetitive, we may charge a reasonable administrative fee or decline to act on the request.
If we have reasonable doubts about the identity of the person submitting a request, we may ask for additional information to verify identity before proceeding.