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 Crown Fundwick (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 give you relevant information, and where we believe you need specific details, we will provide them at the appropriate time. We are also happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy explains the types of Personal Data the Company collects from 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 one who can be identified directly, or indirectly by reference to additional information we hold or are able to access.
1.3 The Policy defines "processing" as 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 learn that we hold information 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 cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information 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. However, withholding such Personal 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 trade: 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 set out 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.
- The Company or a third party may need to process your data to meet a legitimate interest, such as improving Our Services or defending legal claims.
- Processing must meet an obligation of law.
5.3 Contact us by email for more details about the processing necessary to protect the legitimate interests.
5.4 We may use the information you provide for the following reasons and on the following legal grounds:
Scope
Legal Basis
To share your Personal Data with third parties at your request, in order to access digital trading
If you request it, we may collect Personal Data from you to forward to third-party companies.
You have given your consent 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 a third party.
3. To comply with any legal obligation, or any administrative, judicial, or legal requirement, Personal Data is processed to meet applicable legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services. This includes any crash or malfunction reports we collect in relation to the Services.
Where 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, oversight mechanisms, and similar operations.
Where 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 ones, to make decisions on a range of issues.
Processing is necessary for the legitimate interests of the Company or a third party.
8. To protect our assets, rights and interests, and 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 terms, conditions or policies.
Where processing is necessary for the legitimate interests of the Company or 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, IP address information, and analysis of user experiences.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you supply to us to those third-party trading platforms, where its use is governed by their respective 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 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, buyers, or 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 company within the group), 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 on our website or analytics companies. 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 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 last only for a short period until you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to return to the site.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for accessing the features you request and navigating our website. They deliver the information, products, and services you have asked us to provide.
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 save your preferences.
Additional Information
They remain valid until their expiry date and are retained even after you close your browser.
The type of cookie
Cookies for performance
Scope
Cookies help Us collect statistical data on the site's performance and improve it. They also enable Us to analyse our website.
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 Blocking or removing cookies. To prevent or remove cookies, adjust your browser settings. The links below explain the process for a few of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note that some or all of the Website's functions and features may not work as expected 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 personal data with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for a further 12 months.
8.3 We regularly review the Personal Data we hold to confirm it is still needed.
9. International Transfers
9.1 Your personal data may be transferred to other countries, including to a third country or to 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 all residents of 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 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public bodies or authorities under Article 46(2)(a)
- The transfer was carried out in compliance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide information about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this, email: support@crown-fundwick.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational 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, any Personal Data disclosed due to errors in transmission, unauthorised access by a third party, or any other cause 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, such as public authorities. In such cases, we cannot control the security applied to your Personal Data by those third parties.
10.4 No method of transmitting Personal Data over the internet is completely secure. The Company cannot guarantee the security of any Personal Data you transmit 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 the collection or processing of Personal Data by these sites or applications. This Policy does not apply to actions taken through them.
11.2 When you access any third-party websites or apps, we recommend that you read their privacy policies before deciding to use them. We also suggest caution before providing any Personal Data to them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. Any changes will take effect once we post the updated Policy on our website.
12.2 We will also notify you of significant changes to this Policy through methods we consider appropriate and will post an announcement on our website.
12.3 Unless otherwise stated, any amendments take effect once the revised Policy is published.
13. Your Rights
13.1 You may request that we verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.
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 your rights, send an email to the address below.
13.3 Right of access The Company can confirm whether your Personal Data is being processed. If it is, you have the right to access that 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. If 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. Where a request would be detrimental to the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.
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 the 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 have been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation to which the company is subject. This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing 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 the processing of your Personal Data. Where Personal Data is restricted, it may only be retained 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 the Personal Data you have provided to the Company. You may also request that your Personal Data be transmitted 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. This right must not adversely affect the rights and freedoms of others.
13.8 Right to challenge You may 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 establish compelling legitimate grounds for processing, we may continue only unless you can demonstrate that your rights, freedoms, or interests outweigh those grounds, or that processing is necessary for the exercise, establishment, or defence of legal rights. In relation to direct marketing, you have the right at any time to object 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 regarding 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 is needed, we will notify you of it and the reasons within one month of receiving your request.
13.11 Where not prohibited by section 13 of the law, information requested under your section 13 rights will be provided free of charge. If a request is unjustified or excessive, particularly where requests are repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or carrying out 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 that person to provide reasonable means of identifying themselves.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Crown Fundwick 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@crown-fundwick.com