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 website Levyn Digitholm (the "Website").
We want you to be able to make well-informed decisions about how your Personal Data is used and processed. To help with this, we use different methods and processes to share information that is relevant to you. If we believe you need specific details, we will provide them to you at the appropriate time. We are also happy to answer any questions you may have, subject to applicable legal limitations.
1. The Scope
1.1 This policy explains what types of Personal Data the Company collects from individuals, how it uses and processes that data, when it may share it with third parties, and the measures it takes to keep it secure.
1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly or by combining additional information that we hold or can reasonably access.
1.3 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its management, organisation, and storage.
1.4 Our services are meant for a general audience and are not intended for anyone under 18 years of age. We do not knowingly collect or request information from individuals below the age of 18, nor do we knowingly permit them to use our services. If we become aware that we have received information relating to a child, we will delete it as promptly as possible.
2. What Personal Data Do We Have on You
2.1 When you use the service or its channels, or visit our website, we collect Personal Data. In certain cases, we may ask you to provide your Personal Data.
2.2 In certain other cases, we collect your Personal Data by analysing 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 cases, if You choose not to share certain Personal Data, We may be unable to provide the Services, and users may not be able to access the website.
4. What Personal Data We Collect
4.1 This covers details of your online activity log and traffic-related 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 does not constitute personal information and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data that you choose to share with Us when you connect to a third-party online trading platform through Us.
4.4 Personal information that you share directly with 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 process your Personal Data without a valid legal basis. The legal grounds on which the Company may process your Personal Data are as follows:
- You have consented to the processing of your Personal Data for one or more specific purposes. This applies when you submit personal information through the Website so that it can be shared with a third-party trading platform.
- The Company or a third party may need to process data where it is necessary to pursue 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 Set out below are 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-party companies at your request so you can access digital trading
If you request this, we may collect your Personal Data and pass it on to relevant third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, queries, or concerns
We use Personal Data to address any questions you may have about the Services.
The Company’s legitimate interests or those of a third party need to be processed.
3. To comply with any legal, administrative or judicial requirement, Personal Data may be processed as necessary to meet applicable obligations.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including, among other things, crash reports and information about malfunctions that we collect in connection with the Services.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
5. To stop fraud and misuse of Our Services.
The Company’s legitimate interests, or those of a third party, require processing.
6. To carry out and manage activities required for the effective delivery of Our Services
These may include back-office operations, business development initiatives, strategic decision-making, oversight processes, and similar functions.
Processing is necessary to support the legitimate interests of the Company 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 support decision-making on various matters.
The Company’s legitimate interests, or those of a third party, need to be processed.
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 relevant terms, conditions or policies.
Processing is necessary to serve 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, including hosting and storage providers, IP address information providers, and user experience analytics providers.
6.2 You may also ask us to share specific Personal Data relating to you with third-party trading platforms. In such cases, we will provide the Personal Data you have given us to those third-party trading platforms. Their use of 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 its affiliated entities or business partners. This helps the Company access the resources it needs to further improve and enhance the products and services it offers to its customers.
6.4 Where it is necessary to protect the rights of third parties or safeguard assets, the Company may share Personal Data with regulatory, local, or other authorised authorities.
6.5 We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or any other company within the group, if such a transaction takes place (including the transfer or sale of assets owned by the Company or any other group company), or as part of any merger, restructuring, consolidation or insolvency proceedings involving the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may use third-party services, including advertising partners featured 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 enhance your experience, remember your settings, and tailor products and services that may be relevant to you. Cookies are also used for statistical and analytical purposes.
7.3 Some of the cookies we use are session cookies. These are downloaded to your device temporarily and remain active for a limited time, usually until you close your browser. Other cookies are persistent cookies. These stay on your device for a period even 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 to let you access the features you have requested and move around our website smoothly. They help us provide the information, products and services you have asked for.
They are also needed for your device to download and stream data. This enables you to browse the website, use its features, and return to pages you have visited earlier.
Additional Information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are signed 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 save your preferences.
Additional Information
They remain stored until their expiry date, even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical information about the site’s performance and help improve it. They also allow Us to analyse activity on our website.
Additional Information
Cookies may store anonymous information that cannot be linked to any identified or identifiable individual. Some cookies are deleted when you close your browser, while others remain valid for an indefinite period.
7.4 Cookies may be blocked or deleted. To manage or remove cookies, please update your browser settings. Below are links that can guide you through the process for some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please note that if this occurs, some or all features and functions of the Website may not work as expected.
Online Tracking Notice: This service currently does not support do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data only for as long as necessary to fulfil the purpose for which it is processed, as set out in this Policy, or for a longer period where permitted under applicable law, regulations, policies, or relevant orders.
8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
8.3 We review the Personal Data we hold on a regular basis to ensure it is no longer required.
9. International Transfers
9.1 Your personal information may be transferred to other countries (that is, your personal data may be shared with entities in other jurisdictions or with international organisations). The Company takes all necessary measures to protect the Personal Data you provide and to ensure that users can exercise 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 an international organisation that has been recognised as providing an adequate level of protection for Personal Data transferred to it, in line with applicable data protection laws.
- The transfer is carried out under a legally binding and enforceable agreement between public bodies or authorities, in line 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 may provide details of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Please email: support@levyn-digitholm.com
10. Security of Personal Data
10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. These measures include safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee that your Personal Data will always remain completely secure or that its protection will be free from errors. We also cannot be held liable for any indirect, incidental or consequential loss or damage arising from the use or disclosure of Personal Data. This includes, without limitation, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other circumstances beyond our reasonable control.
10.3 If we are required by law, or due to circumstances beyond our reasonable control, we may need to share your Personal Data with third parties, including public authorities. In such cases, we are unable to control how those third parties protect your Personal Data.
10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. 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 monitored or controlled by the Company. We are not responsible for how such websites or applications collect or process Personal Data. This Policy does not apply to any actions taken on or through those websites or applications.
11.2 Before accessing or using any third-party website or app, we recommend that you read its privacy policy carefully. We also advise you to consider this before sharing any Personal Data with them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If any changes are made, we will inform you by publishing the revised Policy on our website.
12.2 In addition, if we make any material changes to this Policy, we will make reasonable efforts to notify you through the channels we consider appropriate and will also post a notice on our website.
12.3 Unless stated otherwise, any changes will take effect once the updated Policy is published.
13. Your Rights
13.1 You have the right to ask us to confirm whether we are collecting your Personal Data, correct any inaccuracies, and delete any Personal Data that we no longer need. You may also request that we limit certain types of processing of your personal information.
13.2 If you are a resident of the EEA, please refer to this page. You may exercise these rights in relation to the Personal Data you provide by sending an email to the address below.
13.3 Access rights The Company may verify whether your Personal Data is being processed. If it is, you have the right to access 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 data will be provided in electronic form. The right to access Personal Data must not adversely affect the rights and freedoms of others. If a request is likely to prejudice another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can comply.
13.4 Right to rectification The Company may correct any inaccurate Personal Data. You also have the right to request correction of any incomplete Personal Data relating to you, taking into account the purpose for which it is being processed.
13.5 Right to Erasure This right may apply in the following situations: (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 valid legal basis for processing; (c) You object at any time, for reasons relating to Your particular situation, to the processing of Your Personal Data where such processing is based on legitimate interests pursued by Us or by 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 applicable to 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 such a restriction, the Personal Data may then be retained only 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 reason of public interest 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 in a structured, commonly used and machine-readable format. You may also request that your Personal Data be transferred directly from 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 any other person.
13.8 Right to challenge You have the right, at any time, to object 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 such processing unless you show that your rights, freedoms, or interests override those grounds, or that the processing is required for the establishment, exercise, or defence of legal claims. In relation to direct marketing, you may object at any time to the processing of your Personal Data.
13.9 Right to refuse consent You may withdraw your consent for Us to process your Personal Data at any time. This will not affect the validity or lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to file a complaint with the relevant supervisory authority. Where applicable, you may approach a competent supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data. Applicable laws may restrict certain rights relating to your Personal Data, as described 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. Where 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 inform you within one month of receiving your request, along with the reasons for the delay.
13.11 Subject to the provisions of section 13 of the law, the information you request in exercise of your rights under section 13 will be provided free of charge. However, if the request is unfounded or excessive, especially in the case of repeated requests, 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.
13.12 If we have reason to doubt the identity of the person who submitted your request, we may ask the individual making the request to provide reasonable proof of identity.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Levyn Digitholm 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@levyn-digitholm.com