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 Pillar Vestmoor (the "Website").
We want you to make informed decisions about how your Personal Data is used and processed. To support this, we apply a range of methods and procedures to give you relevant information. Where we believe specific details are needed, we will provide them at the appropriate time. We are also glad to answer any questions you may have regarding limitations imposed by law.
1. The Scope
1.1 This policy describes the types of Personal Data the Company collects from individuals, and how that data is processed, shared with third parties, and secured.
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 combining additional information we hold or are able to 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 anyone under 18, nor do we knowingly permit such persons to use our services. If we discover that we hold any 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 our services and channels or visit our website. In certain cases, 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 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. However, in certain circumstances, 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 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.
- The Company or a third party may process personal data to serve 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 on the processing necessary to protect our 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 information with third parties at your request to access digital trading
If you request it, we may collect Personal Data from you to forward it 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 address any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or those of 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.
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 perform and manage operations consistent with the requirements of Our Services
These include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar activities.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To perform analysis, including statistical analysis
We apply various analytical techniques, including statistical methods, to make decisions on different matters.
Processing is necessary for the legitimate interests of the Company or 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 compliance with applicable laws, regulations, agreements, and any related conditions, terms or policies.
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 providers who deliver services to us, such as hosting and storage providers, including IP address information, as well as the analysis of user experiences.
6.2 You may 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 give us to those third-party trading platforms. The use of your Personal Data is then 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 the resources 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, buyers, or lenders to the Company or any other company within the group, in connection with a transaction such as the transfer or sale of assets belonging to the Company or any 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 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 the user experience, remember your settings, and tailor the products and services you may enjoy. 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 once you close your browser. Others are persistent cookies, which remain on your device after you close your browser. They help the Website recognize you as a returning visitor and make it easier for you to return to the site.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you request and to navigate our website. They deliver the information, products, and services you have asked us to provide.
They are also required for your device to download and stream data, allowing you to 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. These are deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you on each visit and save 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
We use cookies to collect statistics on site performance and to help improve it. They also allow Us to analyze how our website is used.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable individual. Some cookies are deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, you need to change your browser settings. The links below explain the process for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note that if this occurs, some or all of the Website's functions and features may not work as expected.
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 fulfill 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 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 third countries or international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can exercise their rights and access effective legal recourse.
These protections and safeguards apply 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 entities or authorities, in line with 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 Upon request, the Company will provide details of the security measures applied to safeguard your Personal Data transferred to third-party countries or international organisations. Email: support@pillar-vestmoor.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. We are also not liable 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 through transmission errors, unauthorised access by a third party, or any other cause beyond our control.
10.3 Due 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 these situations, we cannot control the security applied to your Personal Data by those third parties.
10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to Us via the internet.
11. Hyperlinks to Third Party Websites
11.1 The website may contain links to third-party sites and applications that operate outside the Company's control. We are not responsible for how these sites or apps collect or process Personal Data. This Policy does not apply to any actions taken through them.
11.2 When you access third-party websites or apps, we recommend reading their privacy policies before deciding to use them. We also suggest exercising caution before providing any Personal Data to them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. When changes are made, we will notify you by posting the updated Policy on our website.
12.2 If we make significant changes to this Policy, we will notify you through methods we consider appropriate and publish an announcement on our website.
12.3 Unless otherwise stated, any amendments take effect upon publication of the revised Policy.
13. Your Rights
13.1 You may request that We verify the accuracy of the Personal Data collected 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 Data.
13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide regarding your Personal Data. To exercise your rights, send an email to the address below.
13.3 Access rights The Company can confirm whether Personal Data concerning you is being processed. If it is, you may 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 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. If a request would harm the rights and freedoms of another person, the Company may refuse to comply or limit the extent to which it fulfills the request.
13.4 Right to rectification The Company may rectify inaccurate Personal Data. You have the right to request rectification of any incomplete Personal Data concerning you, 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 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 the company's legal obligation. This right does not apply where processing is necessary (a) to fulfil a legal obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Restriction of processing If you are concerned about the accuracy of your Personal Data, you can ask the Company to restrict its processing. Where restriction applies, your Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, or to protect the rights of another natural person, or for reasons of significant 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 a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You may also 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 or freedoms of others.
13.8 Right to object You have the right at any time to object to the use 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 processing, we may continue to process the Personal Data unless you can show that your rights, freedoms, or interests prevail, or that the processing relates to the establishment, exercise, or defense of legal claims. You also have the right at any time to object to the processing of Personal Data concerning you for direct marketing 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 before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may appeal to 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 regarding Personal Data about you, as set out in this section 13.
13.10 We will provide the information you request under your rights in Section 13 of this agreement within one month of receiving your request. Depending on the nature and volume of requests, this period may be extended by up to two months. We will notify you of any extension, along with the reasons, within one month of receiving your request.
13.11 Provided it does not conflict with section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If a request is unfounded 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 them to provide reasonable proof of identity.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Pillar Vestmoor 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@pillar-vestmoor.com