Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about individuals, and how that data is processed, shared with third parties, and secured.

This Policy covers information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly, or through a combination of additional information we hold or can reasonably access.

1.3 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not available to anyone under the age of 18. We do not knowingly collect information from persons under 18, and we do not permit such persons to use our services. If we become aware that we hold information relating to a child, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our services, channels, or website, we collect personal data. We may also request personal data from you in specific circumstances.

2.2 We also collect your personal data by analysing how our Services and service channels are used, or by receiving your information from third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide us with personal data. However, withholding it may prevent us from delivering the Services or restrict your access to the website.

4. What Personal Data We Collect

The information collected is not personal 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 connecting with a third-party online trading platform through us.

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

For more information on the processing required to protect legitimate interests, please contact us by email.

5.4 The following outlines the reasons and legal grounds on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share personal data with third-party service providers, including hosting and storage providers, IP address data handlers, and user experience analytics platforms.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us to those platforms. Your Personal Data will then be governed by their respective privacy policies. Please note that your Personal Data may be shared with more than one third-party trading platform.

6.3 The Company may share Personal Data with related entities or business partners to support the enhancement and improvement of its products and services.

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

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 a transaction involving the transfer or sale of Company assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business within the group.

7. Cookies and Services from Third Parties

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

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical and analytics purposes.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the Website recognise you as a returning user and allow you to access the website again without starting from scratch.

7.5 Please note that disabling certain features may cause parts or all of the Website to function differently than expected.

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

8. Retention of 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.

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

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

Your personal data may be transferred to other countries or shared with international organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@firmholdaventry.com

10. Security of Personal Data

We have implemented appropriate organizational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or modification.

We cannot guarantee that your Personal Data will be kept secure without error, and we are not liable for any incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.

10.3 Where legal or other obligations beyond our control require it, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how these sites or apps collect or process personal data. This Policy does not apply to any actions taken through such third-party sites or applications.

11.2 When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Exercise caution when sharing any personal data with them.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be reflected in the updated Policy posted on our website.

12.2 When significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless otherwise specified, any amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You have the right to request verification of the accuracy of your Personal Data, correction of any errors, and deletion of any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.

If you are a resident of the EEA, please refer to this page for information on your rights regarding your Personal Data. To exercise any of these rights, send a written request to the email address below.

13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of your Personal Data upon request and may charge a reasonable fee for additional copies. This right is subject to the rights and freedoms of others. Where fulfilling a request would infringe on another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request the correction of incomplete Personal Data relating to you, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request the erasure of your Personal Data in the following circumstances: (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 to process; (c) you object, based on reasons specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to fulfil a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law, including under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where a restriction is in place, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or where there is a significant 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 a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used 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. The right to data portability does not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right, at any time, to object to the processing of your Personal Data where that processing is based on the legitimate interests of the Company or a third party. This right is not limited to profiling based solely on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal rights, we may continue to process your Personal Data despite your objection. Concerning direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to Refuse Consent You may withdraw your consent for Us processing Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may also lodge a complaint with a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and its member states may limit your rights in relation to your Personal Data, as set out in this section 13.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two additional months. If an extension is needed, we will notify you within one month of receiving your request and provide the reasons for the delay.

Subject to section 13 of the law, information provided in response to your rights requests will be supplied free of charge. Where a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

13.12 If we have reasonable doubt about the identity of the person submitting a request, we may ask that individual to provide suitable means of verification.