Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects from natural individuals, and how it processes, shares, and secures that data.

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 indirectly by reference to additional information that we hold or are able to 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 individuals to use our services. If we become aware of any information relating to 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 use our service and channels or visit our website. In certain cases, we may request your Personal Data.

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 the 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. This includes 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, and in accordance with the applicable legal basis.

5.3 Email us for more details about the processing required to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

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

6.2 You can also request that we share specific Personal Data about you with third-party trading platforms. Where you ask us to do so, we will provide the Personal Data you have given 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 more than one trading platform.

6.3 The Company may share Personal Data with related entities or business partners. This gives the Company the resources to enhance and improve the products and services it provides to its customers.

6.4 Where necessary to protect the rights of third parties or assets, 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, in connection with such a transaction (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 placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

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

7.5 Please be aware that if this happens, 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 Personal Data about you for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you agree, 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 required.

9. International Transfers

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

9.3 The Company can provide details of the security measures used to protect your Personal Data when it is transferred to third countries or international organisations. Email: support@ledger-bryn.org

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to safeguard Personal Data, including protection against accidental or unlawful destruction, loss or alteration.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held accountable 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 Where required by legal or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security applied to your Personal Data by those third parties.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that fall outside the Company's control. We are not responsible for how these sites or applications collect or process Personal Data, and this Policy does not apply to any actions taken through them.

11.2 Before accessing or using any third-party website or app, we recommend that you read its privacy policy. We also advise caution before 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 Where we make significant changes to this Policy, we will notify you by methods we consider appropriate and publish an announcement on our website.

12.3 Unless otherwise stated, 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 hold about you, correct any inaccuracies, 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 reside in 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, please submit a request by email to the address below.

13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data 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. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply 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 any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (a) the 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, on grounds relating to your particular situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where the processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or Member State law; or (b) to establish, exercise or defend legal claims.

13.6 Restricting processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of 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 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 transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. This right 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. This includes profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing, we may continue unless you can show that your rights, freedoms, or interests outweigh those grounds, or that the processing is necessary for the exercise, establishment, or defence of legal rights. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This will not affect the lawfulness of any processing carried out under your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may appeal to 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 are entitled to under section 13 of this agreement within one month of receiving your request. Depending on the nature and number of requests, this period may be extended by up to two months. If an extension applies, we will notify you within one month of receiving your request and explain the reasons.

13.11 Provided that it does not conflict with the provisions of 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, in particular because it is repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or carrying out the action requested. We may also decline to act.

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