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 kept secure.

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

1.3 For the purposes of this Policy, "processing" means 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 designed for use by anyone under the age of 18. We do not knowingly collect information from or permit use of our services by persons under 18. Should we become aware that such information has been collected, 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 certain circumstances.

2.2 In other cases, we 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 any personal data. However, withholding it may prevent us from delivering the Services or granting you 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 provide to us at your own discretion when connecting to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading: this 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 set out in this section, in accordance with the applicable legal basis.

For further details on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following sets out the purposes and legal bases 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, for purposes such as IP address management and user experience analysis.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms accordingly. Your Personal Data shared in this way will be subject to the privacy policies of the respective third parties. Please note that 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 where this supports the development and improvement of the products and services provided to customers.

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 official authorities.

We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other group company, in connection with a transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or insolvency process affecting the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third parties, such as advertisers and analytics providers, who operate on our website and may use cookies or similar technologies.

7.2 Cookies are small text files placed on your device when you visit the website. They are used to understand your browsing preferences, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytical purposes.

Some cookies used on this Website 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 after your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you pick up where you left off.

7.5 Please be aware that disabling cookies may affect the functionality of certain features or the Website as a whole.

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

8. Retention of Personal Data

We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected, as described in this Policy, or for such longer periods as permitted by applicable law, regulation, or order.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

8.3 We periodically review the personal data we hold to confirm it is no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect your personal data and ensure that individuals retain effective rights and legal recourses.

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

10. Security of Personal Data

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

We cannot guarantee that your Personal Data will be kept secure without error, nor can we accept liability for any indirect, 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 reasonable control.

10.3 Where we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over how those third parties protect your Personal Data.

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

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These sites and applications 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 such sites or applications.

When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. You should also exercise caution when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. Any changes will be communicated by publishing the revised Policy on our website.

12.2 When we make significant changes 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 being collected, to have any inaccuracies corrected, and to request 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 details on your rights in relation to your personal data. To exercise any of these rights, please contact us at the email address below.

13.3 Access rights You have the right to confirm whether the Company is processing Personal Data about you and, if so, to access that Personal Data. The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for additional copies. The right of access must not infringe on the rights and freedoms of others. Where a request would be detrimental to 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 that incomplete Personal Data relating to you be corrected, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer necessary 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 to the processing of your Personal Data where that processing is based on legitimate interests pursued by Us or 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 binding on the company. This right does not apply where processing is necessary (a) to comply with a legal obligation 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 such a restriction is requested, 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 substantial public interest reason 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 your Personal Data in a structured, commonly used format and to request that it be transferred directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability shall not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those 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 claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for such purposes.

13.9 Right to withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent prior to 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 the rights set out in section 13 of this agreement 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 received. We will notify you of any extension, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — in particular where it is repetitive — 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 on the request.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask them to provide suitable means of verifying their identity.