Privacy Policy

Our Beginning

We – referred to as 'We' or 'Our' – are committed to protecting your personal data and privacy.

This privacy policy is designed to explain how we collect, store, process, and use the information you provide in connection with the website Strovemont Trust (hereinafter the 'Website').

We commit to following these principles:

Transparency in the collection and processing of your personal data:

We ensure you are always well-informed so you can make conscious choices about how your data is used on the website or when interacting with third-party platforms. We use various methods to provide you with accurate and timely information about the processing of your data.

If we need to give you specific information, we ensure this is delivered at the appropriate time and place.

We are also available to answer questions or provide clarifications, within the limits of applicable law. You can reach us by email: [email protected]

Processing of personal data only for the purposes stated in this policy:

We may process your data to make the website available, connect you with third-party trading platforms ('the Services'), improve user experience, develop the platform, protect our rights, carry out administrative processes, and comply with legal requirements.

We also process information to better understand your needs and preferences.

Resources to safeguard your rights:

We allocate significant resources to ensure you can exercise your rights as a data subject. You may at any time request access, rectification, erasure, or restriction of your data, or request that it be transferred. We will respond in accordance with applicable law.

Protection of your personal data:

While we cannot guarantee absolute security, we employ modern security methods and measures to protect your data and will continue to enhance these.

Our Full Privacy Policy

1. Scope

This policy describes the types of data we collect, how we process it, share it with third parties, and the security measures we apply.

'Personal Data' means any information that can be linked to an identified or identifiable person. 'Processing' means any operation such as collection, storage, use, sharing, modification, or deletion.

Our services are intended for a general audience and are not directed at individuals under 18. We do not knowingly collect information from minors. If we discover such information has been recorded, we will delete it promptly.

2. When Do We Collect Information?

We collect data when you use our services, visit the website, or interact with our channels. Some information you provide directly; other data is collected automatically through analysis of your activity or via third-party partners.

3. No Obligation to Provide Data – But Consequences

You are not required to provide us with data. However, without certain data, we may not be able to offer you all our services or give you full access to the website.

4. What Types of Information Do We Collect?

This may include activity logs, IP addresses, timestamps, language, browser type, device information, and error logs. Some of this may not directly identify you and is therefore not considered personal data.

Information you provide directly: name, phone number, email address when you contact us or use the platform.

5. Purposes of Processing and Legal Basis

Strovemont Trust processes data only when we have a legal basis, such as to provide services, improve experience, protect your data, or comply with legal obligations.

• You have given consent to the processing of your personal data for specific purposes. This applies when you knowingly share information via the website so we can forward it to a third-party trading platform.
• Processing is necessary for the legitimate interests pursued by Strovemont Trust or a third party. For example, this may include improving our services or handling legal claims.
• Processing is necessary to comply with a legal obligation to which Strovemont Trust is subject.

If you would like further explanation of how processing of your personal data serves the legitimate interests of Strovemont Trust or a third party, you may contact us by email at any time.

Below is an overview of why we may process your data, along with the legal bases:

6. Transfer of Personal Data to Third Parties

Strovemont Trust may share your data with third-party providers who assist with storage, hosting, IP information, user experience analysis, research, and other technical or diagnostic services.

If you request it, we may also transfer certain data to third-party trading platforms. In such cases, these will process the data in accordance with their own privacy policies. We may share data with multiple trading platforms.

Strovemont Trust may also share data with affiliated companies and business partners who help improve the quality of our services.

We may disclose data to public authorities if necessary to protect our or third-party interests, rights, or assets, including in connection with legal proceedings.

Data may also be shared with potential buyers, investors, or lenders in connection with mergers, acquisitions, reorganisations, or bankruptcy proceedings.

7. Cookies and Third-Party Services

We use certain third-party services, such as analytics and advertising providers. These may use cookies or similar technology, governed by their own policies.

A cookie is a small text file stored on your device when you visit the website. It may collect information about usage patterns, preferences, and technical data, and is used to improve your experience, remember settings, and deliver more relevant content.

We may use both session cookies (deleted when the browser is closed) and persistent cookies (remaining on your device until they expire or are manually deleted).

Types of Cookies:

Blocking and Deleting Cookies

You can change your browser settings to block or delete cookies. Here are links to instructions for the most commonly used browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some features of the website may stop working if you block cookies.

NOTE ON ONLINE TRACKING

This service currently does not support 'Do Not Track' signals.

8. Storage of Personal Data

Strovemont Trust will store your data for as long as necessary for the purposes described in this policy, or as required by law, regulation, or authority.

If you have consented, we may share data with third-party trading platforms for up to 12 months, with the possibility of extension upon renewed consent.

We regularly review stored data to ensure it is not kept longer than necessary.

9. Transfer of Personal Data to Third Countries or International Organisations

Your personal data may be transferred to a third country (outside the EEA) or to international organisations. In such cases, Strovemont Trust will implement necessary safeguards to ensure data protection and that your rights and effective remedies are maintained.

If you are resident in the EEA (European Economic Area), such protective measures apply if one of the following criteria is met:

• The transfer is to a third country or international organisation that the European Commission has recognised as having an adequate level of data protection, pursuant to GDPR Article 45(3).
• The transfer is based on a legally binding and enforceable agreement between public authorities or bodies, pursuant to GDPR Article 46(2)(a).
• The transfer is based on standard data protection clauses adopted by the European Commission, pursuant to GDPR Article 46(2)(c). These clauses are available on the European Commission's website.

If you would like more information about the safeguards we use when transferring personal data, you can contact us by email: [email protected]

10. Protection of Personal Data

We use technical and organisational security measures to protect personal data against unauthorised access, alteration, loss, or destruction. These measures are adapted to the risk posed by processing.

We cannot guarantee absolute security for data transmitted over the internet. Strovemont Trust disclaims liability for indirect or incidental damages that may arise from data loss or unauthorised access beyond our reasonable control.

In some cases, we may be legally obliged to share data with public authorities. In such cases, our control over the protection of the data may be limited.

11. Links to Third-Party Websites

The website may contain links to external websites or applications operated by third parties. Strovemont Trust has no control over these and is not responsible for their processing of personal data. We recommend that you always read their privacy policies before providing any information.

12. Your Rights Regarding Personal Data

You have the right to request access to the data we process about you, to request correction of errors, to request deletion of data that is no longer necessary, and to restrict or withdraw consent for certain processing.

Right of Access

You have the right to obtain confirmation as to whether Strovemont Trust processes personal data concerning you. If we do, you have the right to access the data and information about: purposes, categories of data, recipients (including in third countries), storage period, rights, the right to lodge a complaint, and what safeguards have been implemented for transfers.

You may receive a copy of the data being processed. If you request additional copies, we may charge a reasonable fee. If the request is submitted electronically, the data will normally be provided in a commonly used electronic format.

The right of access shall not adversely affect the rights and freedoms of others. If this occurs, we may restrict access or refuse the request.

Right to Rectification

You may request that Strovemont Trust rectify inaccurate or incomplete data concerning you. If necessary, you may provide a supplementary statement.

Right to Erasure ('Right to be Forgotten')

You have the right to request erasure of your data when it is no longer necessary for processing, when you withdraw consent, or when processing is unlawful. We will respond in accordance with applicable law.

Right to Erasure ('Right to be Forgotten')

This right applies if: (a) the personal data is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or a third party's legitimate interests, and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the data has been unlawfully processed; or (f) the data must be erased to comply with a legal obligation under EU or UK law.

The right does not apply if processing is necessary (a) to comply with a legal obligation, or (b) for the establishment, exercise, or defence of legal claims.

Right to Restriction of Processing

You may request that we restrict processing of your data if: (a) you contest the accuracy, for a period allowing us to verify; (b) processing is unlawful, but you prefer restriction over erasure; (c) we no longer need the data, but you require it for legal claims; (d) you have objected to processing, pending verification of our legitimate interests; (e) data is processed for direct marketing, including profiling.

If processing is restricted, the data may only be used with your consent, for legal claims, to protect the rights of others, or for reasons of important public interest.

Right to Data Portability

You have the right to receive personal data you have provided to us in a structured, commonly used, and machine-readable format. You may also request that we transfer the data directly to another controller where technically feasible, and where processing is based on consent or contract and carried out by automated means.

Right to Withdraw Consent

You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to Object

You may object to processing of your data when processing is based on legitimate interests. This also applies to profiling. We will then stop processing unless we demonstrate compelling legitimate grounds that override your interests and rights, or where processing is necessary for legal claims.

You may also object at any time to processing of data for direct marketing, including profiling related to such marketing.

Right to Lodge a Complaint with a Supervisory Authority

You may lodge a complaint with the Information Commissioner's Office (ICO) or another supervisory authority within the EEA if you believe that the processing of your personal data infringes the GDPR.

We will respond to requests to exercise rights within one month of receipt. If necessary, the period may be extended by up to two months, depending on the complexity of the case and the number of requests. You will be informed of the reason for the delay.

Information relating to the exercise of rights is provided free of charge, unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse the request.

Strovemont Trust may request additional information to confirm your identity if we have reasonable grounds to doubt it.

13. Updates to This Policy

We reserve the right to update this privacy policy. Changes will be published on the website, and material updates will be communicated clearly. Unless otherwise stated, changes take effect when the updated policy is published.