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 (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy. This Privacy Policy explains how we collect and store the information you provide through the Sovereign Kapitix website (the "Website").
We want you to be able to make informed decisions about how your Personal Data is used and processed. We use a range of methods and procedures to provide you with relevant information. Where we consider that you need particular details, we will provide them at the appropriate time. We are happy to answer any questions you may have, subject to any legal limitations.
1. The Scope
1.1 This policy outlines the types of Personal Data the Company collects about individuals and how it is processed, shared with third parties, kept secure, and otherwise managed.
1.2 This Policy applies to information relating to an identified or reasonably identifiable individual. An individual is reasonably identifiable if they can be identified directly, or by combining the information with other details we hold or can access.
1.3 In this Policy, "processing" refers to any activity that involves the use or collection of Personal Data, including the handling, organisation and storage of Personal Data.
1.4 Our services are intended for a general audience and are not designed for anyone under 18 years of age. We do not knowingly collect information from anyone under 18 or permit them to use our services. If we become aware that we hold information relating to a child, we will delete it as soon as reasonably practicable.
2. What Personal Data Do We Have on You
2.1 When you use our services and channels, or visit our website, we collect Personal Data. In some circumstances, we may ask you to provide your Personal Data.
2.2 In other cases, we collect your Personal Data by reviewing how you use 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. However, in some circumstances, choosing not to provide certain Personal Data may prevent us from delivering the Services or may affect users’ ability to access the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity and traffic data, including:
- 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 collected 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 to a third-party online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to enable trading: 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 and in line with the applicable legal basis.
5.2 The Company cannot use your Personal Data unless there is a lawful basis for doing so. The legal bases 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 provide personal information through the Website so that we can pass it on to a third-party trading platform.
- The Company or a third party may need to process your information where this is necessary to support their legitimate interests, such as improving Our Services or establishing, exercising or defending legal claims.
- Processing must meet an obligation of law.
5.3 For more information about the processing required to protect legitimate interests, please contact us by email.
5.4 The following outlines the reasons and legal bases on which we may use the information you provide to us:
Scope
Legal Basis
1. To share your personal information with third parties at your request so you can access digital trading
If you request this, we may ask you to provide Personal Data so we can pass it on to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your enquiries, questions or concerns
We require Personal Data so we can address any questions you may have about the Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
3. Personal Data is processed to comply with any legal, regulatory, administrative or judicial obligation.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services Personal
Data may be used to help us improve Our Services. This includes, among other things, any crash reports or malfunction reports we collect in connection with the Services.
The Company’s legitimate interests, or those of a third party, need to be processed.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required to deliver Our Services
This includes back-office operations, business development initiatives, strategic decision-making, oversight processes and related functions.
Processing is necessary to support the Company’s legitimate interests or those of a third party.
7. To carry out analysis, including statistical analysis
We use a range of analytical methods, including statistical techniques, to inform decisions on various matters.
Processing is necessary to support the Company’s legitimate interests or those of a third party.
8. To protect 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 accordance with applicable laws, regulations, agreements, and any relevant terms, conditions or policies.
Processing is necessary to support the Company’s legitimate interests 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 service providers that support our operations, including hosting and storage providers, providers of IP address information, and services that analyse user experience.
6.2 You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these circumstances, we will share the Personal Data you have provided to Us with those third-party trading platforms. How they use your Personal Data will be governed by their own privacy policies. 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. This helps the Company access the resources it needs to enhance and improve the products and services it provides to its customers.
6.4 Where it is necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local or other relevant authorities.
6.5 We may also disclose your Personal Data to prospective investors or purchasers, or to lenders of the Company or any other entity within the corporate group, if a transaction of this kind occurs (including the transfer or sale of assets owned by the Company or another group entity), or as part of a merger, restructure, consolidation or insolvency process involving the Company or any other business in the group.
7. Cookies and Services from Third Parties
7.1 We may use third-party services, including advertising providers on our website and analytics providers. These companies may also use cookies or similar technologies.
7.2 Cookies are small text files stored on your device each time you visit or access the website. They help us understand your preferences and browsing behaviour so we can improve your experience, remember your settings, and tailor products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.
7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for a short time, usually until you close your browser. Other cookies are persistent cookies. These stay on your device for a period after your browser is closed. They help the Website recognise you as a returning user and allow you to access the website again more easily.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for you to access the features you’ve requested and move around our website. We use cookies to deliver the information, products and services you’ve asked for.
They are needed for your device to download and stream data. This allows you to browse the website, use its features, and return to pages you’ve visited before.
Additional Information
Cookies collect Personal Data, including your username and the date of your most recent login, to verify that you’re logged in to the site. These are deleted when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognise you each time you visit our site and remember your preferences.
Additional Information
They remain valid until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies help us collect statistical information about the site’s performance and support ongoing improvements. They also allow us to analyse activity across our website.
Additional Information
Cookies store anonymous information that is not linked to any identified or identifiable individual. Some cookies can be deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies can be blocked or deleted. To manage or remove cookies, you’ll need to update your browser settings. Below are links to help you do this in some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please note that some or all Website functions and features may not operate 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 keep your Personal Data only for as long as needed to carry out the purposes for which it is processed, as set out in this Policy, or for longer where permitted under applicable law, regulations, policies, or orders.
8.2 We will share your information with third-party trading platforms for 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 make sure it is no longer required.
9. International Transfers
9.1 Your personal information may be transferred overseas (that is, your personal data may be disclosed to recipients in other countries or to international organisations). The Company takes all reasonable steps to protect the Personal Data you provide and to ensure you are able to exercise your rights and access effective legal remedies.
These protections and safeguards are available to anyone living in the EEA (European Economic Area):
- Transfer to an overseas recipient or international organisation where the relevant authority has determined that adequate protection is provided for the Personal Data transferred to that recipient.
- The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide details of the security measures it uses to protect your Personal Data when it is transferred to overseas third parties or international organisations. To request this information, please email: support@sovereignkapitix.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 or warrant that your Personal Data will remain secure at all times or be free from error. Nor can we accept liability for any indirect, incidental or consequential loss or damage arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other cause beyond our reasonable control.
10.3 Where we are legally required to do so, or where circumstances outside our control make it necessary, we may disclose your Personal Data to third parties, including public authorities. In these circumstances, we are unable to control how those third parties protect the security of your Personal Data.
10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Hyperlinks to Third Party Websites
11.1 The website may include links to third-party websites and applications. These websites and applications are not controlled or supervised by the Company. We are not responsible for how those websites or applications collect or process Personal Data. This Policy does not apply to any actions taken through those websites or applications.
11.2 Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also suggest considering this before providing any Personal Data to those third parties.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If any changes are made, we will let you know by publishing the revised Policy on our website.
12.2 In addition, if we make any significant changes to this Policy, we will seek to notify you using the communication methods we consider appropriate and will post a notice on our website.
12.3 Unless stated otherwise, any changes will take effect once the updated Policy has been published.
13. Your Rights
13.1 You may ask us to confirm the accuracy of any Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer need. You may also request that we limit the types of processing applied to your personal information.
13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, please email the address below.
13.3 Access rights You are entitled to ask the Company to confirm whether your Personal Data is being processed. Where it is, you may request access to 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. If you request it, the information will be provided electronically. Your right to access Personal Data must not adversely affect the rights and freedoms of others. Where a request would prejudice another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it is able to comply.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You also have the right to request that any incomplete Personal Data relating to you be corrected, having regard to the purpose for which it is being processed.
13.5 Right to Erasure This right applies in the following circumstances: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, 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 has been processed unlawfully; or (f) the Personal Data must be deleted to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under applicable 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 ask the Company to restrict how your Personal Data is processed. Where you request a restriction, the Personal Data may only be retained with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another individual, or where there is an important public interest recognised under applicable law.
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 legal right to receive the Personal Data you have provided to the Company and to review that data. You are also entitled to request that your Personal Data be transferred directly by the Company to another data controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. This right does not override the rights or freedoms of others.
13.8 Right to object You may object at any time to the use of your Personal Data where the processing is based on the legitimate interests of the Company or a third party. This right also applies to profiling carried out on the basis of those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue unless you show that your rights, freedoms or interests override those grounds, or that the processing relates to 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 your Personal Data.
13.9 Right to withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to make a complaint to the relevant supervisory authority. You may lodge a complaint with a supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data. Applicable laws may limit your rights in relation to your Personal Data, 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. If necessary, this period may be extended by up to two additional months, depending on the nature of your request and the number of requests received. If an extension applies, we will let you know within one month of receiving your request and explain the reasons for the delay.
13.11 Provided this does not conflict with the provisions of section 13 of the law, any information you request in exercising your rights under section 13 will be supplied free of charge. If a request is unfounded or excessive, particularly where it is repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act.
13.12 If we have any 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.
Please read this Privacy Policy together with our Term Of Use and Risk Disclosure.
Sovereign Kapitix 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@sovereignkapitix.com