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 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 Roan Fondvale (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 to keep you appropriately informed, and will provide specific details when relevant and at the right time. We're happy to answer any questions you may have about applicable legal limitations.
1. The Scope
1.1 This policy describes the types of personal data the Company collects about natural individuals, and how that data is processed, shared with third parties, and secured.
This Policy covers information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified through a combination of information we hold or can reasonably access.
1.3 For the purposes of this Policy, "processing" means any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.
Our services are intended for general audiences. We do not permit anyone under the age of 18 to use our services, and we do not knowingly collect information from minors. If we become aware that we hold data relating to a person under 18, we will delete it promptly.
2. What Personal Data Do We Have on You
When you access our services, channels, or website, we collect personal data. In certain instances, we may ask you to provide personal data directly.
In some cases, we collect your personal data by analysing how our Services and service channels are used, or by receiving your information from third-party partners.
3. No Requirement to Disclose Personal Information
You are not obliged to provide us with any personal data. However, if you choose not to, we may be unable to provide the Services or grant you access to the website.
4. What Personal Data We Collect
4.1 This includes 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
The information collected is not personal in nature 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 connecting with a third-party online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
Your personal data is processed by the company for the purposes set out in this section, in accordance with the applicable legal basis.
5.2 The Company may only process your personal data where a legal basis exists. The legal grounds on which the Company may rely to process your personal data are:
- You have consented to the processing of your personal data for one or more specified purposes. This applies where you submit personal data through the Website so that it can be passed to a third-party trading platform.
- In some cases, we or a third party may need to process your data to pursue legitimate interests — such as improving our Services or defending legal claims.
- Processing must meet an obligation of law.
For more information on the processing carried out to protect legitimate interests, please contact us by email.
5.4 The following sets out the purposes and legal bases on which we may process the information you provide to us:
Scope
Legal Basis
If you request it, we may collect your personal data and share it with third-party companies to facilitate your access to digital trading.
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 is required to address any questions you may have about the Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, or judicial obligations.
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 crash reports and malfunction data collected in connection with the Services.
Processing data is necessary to serve the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing is required to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
This includes back-office operations, business development, strategic decision-making, and oversight functions.
Processing is required to serve the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas.
Processing in 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 accordance with applicable laws, regulations, agreements, and any relevant conditions, terms, or policies.
Processing is necessary to pursue 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 service providers, including hosting and storage providers, IP address data handlers, and user experience analytics providers.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us to those platforms accordingly. Your Personal Data will then be subject to the privacy policies of the respective third-party platforms. Please note that 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 to support the enhancement and improvement of the products and services provided to customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose personal data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other group company, in connection with a transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may work with third-party service providers, such as advertising networks and analytics companies. These providers may use cookies or similar technologies on our website.
7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your preferences and browsing behaviour, personalise your experience, and remember your settings. Cookies are also used for statistical and analytical purposes.
Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. These are used to recognise you as a returning user and allow you to resume access to the Website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and to navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and allow you to move between pages, use site features, and return to pages you've previously visited.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify that you're logged in. They're deleted automatically when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies recognise you each time you visit our site and remember your preferences.
Additional Information
These cookies persist until their expiry date and remain stored even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on site performance and to carry out analysis that helps us improve your experience.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable individual. Session cookies are removed when you close your browser; others remain valid indefinitely.
7.4 If cookies are blocked or removed, you will need to adjust your browser settings. The links below cover the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note that disabling cookies may affect the functionality of certain or all features on the Website.
Online Tracking Notice: This service does not currently recognise do-not-track signals.
8. Retention of Personal Data
The Company will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or 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.
We periodically review the Personal Data we hold to confirm it is no longer required.
9. International Transfers
9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect the personal data you provide and to ensure that individuals retain the ability to exercise their rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area):
- Transfers to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- This transfer is made under a legally binding and enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
- This transfer was carried out in accordance with standard contractual clauses adopted by the European Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@roanfondvale.com
10. Security of Personal Data
10.1 We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor do we accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
In certain circumstances, we may be legally or otherwise obligated to disclose your personal data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect your personal data.
10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications. These are not operated or supervised by the Company. We are not responsible for the collection or processing of personal data by any such sites or applications. This Policy does not apply to any actions taken through them.
Before visiting any third-party website or app, we recommend reading its privacy policy. Only provide your personal data to third parties once you are satisfied with how it will be used.
12. Modifications to This Policy
This Policy may be updated at any time. Any changes will be communicated by posting the revised Policy on our website.
12.2 When significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.
Unless otherwise specified, any amendments to this Policy take effect upon publication of the revised version.
13. Your Rights
You have the right to request verification of the accuracy of personal data we hold about you, to have any inaccuracies corrected, and to request deletion of any personal data we do not require. You may also restrict the types or scope of processing applied to your personal data.
If you are an EEA resident, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, contact us at the email address below.
13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. This right to access must not infringe on the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of a third party, the Company may refuse or limit its response accordingly.
13.4 Right to rectification The Company may rectify inaccurate Personal Data at any time. You have the right to request that incomplete Personal Data relating to you be corrected, having regard to the purpose for which it is processed.
13.5 Right to Erasure You may request the erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer necessary 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, 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 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 applicable to the company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where a restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or where there is a significant public interest ground 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 right to receive the Personal Data you have provided to the Company in a structured, commonly used format. You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability shall not adversely affect the rights or freedoms of others.
13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.
13.9 Right to Withdraw Consent You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of consent prior to its withdrawal. You have the right to lodge a complaint with a supervisory authority established by an EU member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. EU law and the laws of individual member states may limit the rights described in this section 13.
We will respond to requests made under Section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity and volume of requests received. You will be notified of any extension, and the reasons for it, within one month of your original request.
Subject to the provisions of section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive, particularly where requests are repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or fulfilling the requested action. We may also decline to act on such requests.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide reasonable evidence to verify their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Roan Fondvale 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@roanfondvale.com