Privacy Policy

1. The Scope

1.1 This policy sets out the types of Personal Data the Company collects about natural persons and how it processes, shares with third parties, secures, and otherwise handles it.

1.2 This Policy relates to information connected to an identified or identifiable natural person. An identifiable natural person can be defined as someone who is identified directly or through a combination of additional information we hold or can access.

1.3 The Policy defines "processing" as any activity involving the use or collection of Personal Data. It includes the management, structuring, and storage of Personal Data.

1.4 Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly collect or seek information from anyone younger than 18 years old. We do not knowingly permit such persons to use our services. If we become aware of any information about children, we will delete it as quickly as we can.

2. What Personal Data Do We Have on You

2.1 If you access the service and channels or visit our website, we collect Personal Data. We may ask for your Personal Data in certain circumstances.

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

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide Us with any Personal Data. In certain circumstances, however, you may choose not to supply Us with any Personal Data. This could prevent Us from providing the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.2 The information you collect is not personal information 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 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 Your Personal Data is processed by the company for the purposes set out in this section, and in line with the legal basis applicable to it.

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

5.4 Set out below is a list of reasons and legal grounds on which we may use the information you provide us with:

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, as well as analysis of user experiences.

6.2 You can also ask us to send specific Personal Data about you to third-party trading platforms. In these cases, we will provide the Personal Data you give Us to those third-party trading platforms. The use of your Personal Data is subject to their 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 can provide the Company with the resources it needs to enhance and improve the products and services it offers its customers.

6.4 Where it is 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 prospective investors or buyers, or with lenders to the Company or any other company in the group, if the relevant 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 involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, such as those providing advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period of time after you close your browser. They are used to help the Website identify you as a returning user and allow users to return to the website.

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

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

8. Retention of Personal Data

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

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

8.3 We regularly review the Personal Data we keep to ensure it is no longer needed.

9. International Transfers

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

9.3 The Company can provide information on the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to: support@sterling-vaultmere.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss or alteration of Personal Data.

10.2 We cannot guarantee or warrant 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 law or by other obligations beyond our control, we may need to disclose Personal Data relating to you to third parties, such as public authorities. In these circumstances, we cannot control the security provided for your Personal Data by those third parties.

10.4 Personal Data cannot be transferred over the web in a completely secure way. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party websites and applications are provided on the website. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such websites or apps.

11.2 When you visit any third-party websites or apps, We recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest that you provide them with any Personal Data.

12. Modifications to This Policy

12.1 This Policy may be changed at any time. If we make changes to this Policy, we will notify you by posting the updated Policy on our website.

12.2 In addition, if we make significant changes to this Policy, we will seek to inform you using the methods we consider appropriate and will publish an announcement on our website.

12.3 Any amendments, unless expressly stated, will take effect upon publication of the revised Policy.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 If you are resident in the EEA, please refer to this page. These rights are available to you in relation to the information you provide as part of your Personal Data. You may request to exercise these rights by sending an email to the address below.

13.3 Access rights The Company is able to verify whether Personal Data relating to you is being processed. If it is, you are able to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you ask for it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights and freedoms of another person or their rights, the Company can refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be rectified, taking into account the reason for 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 your Personal Data based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are processed unlawfully or (f) Personal Data must be removed to comply with the company's legal obligation. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that must be processed 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 can ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, it may only be retained with your consent or in order to establish, exercise or defend legal rights, to protect the rights of another natural person, or where there is a reason of significant public interest within the European Union or a Member state.

13.7 Right to data portability If processing is carried out by an automated system and is based on consent or a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right of erasure are not affected by exercising your right to data portability. The right to data portability does not affect the rights or freedoms of any other person.

13.8 Right to challenge You have the right at any time to object to any use of Personal Data relating to you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing Personal Data, we may continue unless you show that your rights, freedoms, or interests override those grounds, or where processing is needed for the establishment, exercise or defence of legal claims. In relation to direct marketing, you have the right at any time to object to the processing of Personal Data relating to you.

13.9 Right to refuse consent You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the legality or lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You have the right to lodge a complaint with the authority that supervises you. You may also appeal to 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 Member States may limit your rights in relation to Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you request under the rights set out in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months, if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will inform you of any extension, as well as the reasons.

13.11 Provided this 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. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request We may ask the person making the request to provide reasonable proof of identity.