TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Forge Capmoor (the "Website").
We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods to provide you with relevant information, and where we believe specific details are needed, we will share them at the appropriate time. We are happy to answer any questions you may have, subject to any limitations imposed by law.
1. The Scope
1.1 This policy explains the type of Personal Data the Company collects about natural persons, and how it processes, shares with third parties, and secures that data.
1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly by combining additional information that 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 any person under 18, nor do we knowingly permit such persons to use our services. If we become aware of any information we hold 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 the service and channels or visit our website. In certain instances, we may request your Personal Data directly.
2.2 In other instances, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information about you 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
4.1 This includes information about your online activity log and traffic data, such as:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
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 trades: 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, in accordance with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- We or a third party may process personal data to meet a legitimate interest, for example to improve Our Services or to defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact us by email for further details on the processing necessary to protect our legitimate interests.
5.4 We may use the information you provide for the following reasons and legal grounds:
Scope
Legal Basis
To provide your Personal Data to third parties at your request for access to digital trading
If you request it, we may collect Personal Data from you to forward to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions or concerns
Personal Data helps us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
To comply with legal obligations or administrative, judicial, or regulatory requirements, Personal Data is processed to meet those requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
These include back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We apply various analytical techniques, including statistical methods, to inform our decisions on a range of issues.
Processing is necessary for the legitimate interests of the Company or a third party.
8. To safeguard our assets, rights and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
Processing is necessary for the legitimate interests of the Company or those of a third party.
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, including 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. In these instances, we will provide the Personal Data you have given us to those third-party trading platforms. The use of your Personal Data is governed by 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 gives the Company access to the resources needed 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, where such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other group company), 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 third parties may also use cookies or similar technology.
7.2 Cookies are small text files placed 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 of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. Persistent cookies help the Website recognise you as a returning user and allow you to return to the website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you have requested and to navigate our website. They are used to deliver the information, products and services you have asked us for.
They also allow your device to download and stream data, so you can move around the website, use its features, and return to pages you have visited before.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm that you are logged in to the site. They are erased once you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognise you on each visit and to remember your preferences.
Additional Information
They remain until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on the site's performance and to help us improve it. They also allow us to analyse how our website is used.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, adjust your browser's settings. The links below explain the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please note that some or all of the Website's functions and features may not work as you expect if this occurs.
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 fulfil 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 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 ensure it is still required.
9. International Transfers
9.1 Your personal data may be transferred to other countries, including to a third country or 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.
These protections and safeguards are available to everyone residing in the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made under a legally binding and enforceable agreement between public bodies or authorities in the viro Article 46(2)(a)
- The transfer was carried out in compliance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide details of the security measures used to protect your Personal Data when it is transferred to third-party countries or international organisations. Email: support@forge-capmoor.com
10. Security of Personal Data
10.1 We have implemented appropriate organisational 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. 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, Personal Data disclosed through transmission errors, unauthorised access by a third party, or any other cause beyond our control.
10.3 Where legal or other obligations beyond our control apply, we may be required to disclose your Personal Data to third parties, such as public authorities. In these situations, we cannot control how those third parties protect your Personal Data.
10.4 Personal Data cannot be transmitted over the internet in a completely secure way. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these sites or applications. 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 This Policy may change at any time. If we make changes, we will notify you by posting the updated Policy on our website.
12.2 We will also inform you of any significant changes to this Policy using the methods we consider appropriate, and we will publish a notice on our website.
12.3 Unless otherwise stated, any amendments take effect once the revised Policy is published.
13. Your Rights
13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the 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 them, please send an email to the address below.
13.3 Access rights You may ask the Company to confirm whether your Personal Data is being processed. If it is, you have the right 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. Where 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. If 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 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 at any time, on grounds relating to your particular 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 comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil a legal obligation required to be processed under European Union law or Member State law; or (b) to establish, exercise or defend legal claims.
13.6 Restriction of processing If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, the Personal Data may only be kept 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 a copy of the Personal Data you have provided to the Company. You may 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 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 the processing, we may continue to process your Personal Data only if those grounds override your rights, freedoms, or interests, or where the processing is for the establishment, exercise, or defence of legal claims. In relation to 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 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 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 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 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 inform you of it, along with the reasons, within one month of receiving your request.
13.11 Where consistent with section 13 of the law, the information you request under your section 13 rights will be provided free of charge. If a request is unfounded or excessive, in particular where it is repetitive, we may charge a reasonable fee to cover the administrative cost 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 them to provide reasonable means of verifying their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Forge Capmoor 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@forge-capmoor.com