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 known as "We", "Us", or "Our") are committed to protecting your personal data and privacy. This Privacy Policy explains how we collect and store information you provide through the website Royal Sparforge (the "Website").
We want to ensure you can make informed decisions about how your Personal Data is used and processed. We use various methods to keep you informed with relevant details. When we believe you need specific information, we'll provide it at the right time. We're happy to answer any questions about legal limitations that may apply.
1. The Scope
This policy outlines the types of Personal Data the Company collects from individuals and explains how it processes, shares with third parties, and secures such data.
This Policy covers information related to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified, or can be identified through a combination of additional information we hold or can access.
1.3 The Policy defines "processing" as any activity involving the use or collection of Personal Data. This includes managing, organising, and storing Personal Data.
Our services are intended for general audiences and are not designed for individuals under 18 years of age. We do not intentionally collect information from anyone younger than 18. We do not knowingly permit such individuals to use our services. If we become aware of any information belonging to minors, we will remove it promptly.
2. What Personal Data Do We Have on You
When you access our service, channels, or website, we collect your Personal Data. In certain cases, we may also request additional Personal Data from you.
In some cases, we collect your Personal Data by analysing how you use our Services and service channels, or by receiving information about you from our third-party partners.
3. No Requirement to Disclose Personal Information
You are not required to provide Us with any Personal Data. However, in certain circumstances, if you choose not to share Personal Data with Us, it may prevent Us from delivering the Services or may restrict your access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and data regarding your traffic, 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 you collect is not considered private information and cannot be used to identify you.
Personal data you provide to us voluntarily when you connect to a third-party online trading platform through our service.
4.4 Personal information you provide to third-party trading platforms: 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 outlined in this section, in accordance with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a legal basis. The following are the legal grounds upon which the Company may process your Personal Data:
- 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 pursue their legitimate interests—for example, to improve our Services or defend against legal claims.
- Processing must meet an obligation of law.
5.3 Contact us via email for more details about the processing required to protect legitimate interests.
5.4 Below is a list of the reasons and legal grounds under which we may use the information you provide to us:
Scope
Legal Basis
We may request your personal information to share with third-party companies if you request access to digital trading services.
You have consented to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions or concerns
Personal Data is necessary to help us respond to any questions you might have about the Services.
The Company or a third party may need to process legitimate interests for operational purposes.
3. To meet legal obligations, we process Personal Data as required by administrative, judicial, or other legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services, we may use your Personal Data. This includes crash reports and malfunction information we collect related to the Services.
The Company or a third party's legitimate interests require the processing of your data.
5. To stop fraud and misuse of Our Services.
The Company or a third party may need to process certain legitimate interests.
6. To carry out and manage activities that align with the requirements of Our Services
This includes back-office functions, business development activities, strategic decision-making, oversight mechanisms, and similar operations.
The Company or a third party may need to process personal data based on legitimate interests.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different issues.
The Company or a third party's legitimate interests require processing of personal data.
To safeguard our assets, rights and interests as well as those of third parties
we may process Personal Data in accordance with applicable laws, regulations and agreements, and relevant terms, conditions and policies.
The Company or a third party may need to process legitimate interests for business or legal purposes.
6. Transfer of Personal Data to Third Party
The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, including IP address information and user experience analytics.
6.2 You can request that we share your Personal Data with third-party trading platforms. When you do, we will provide your Personal Data to these third-party platforms. Their use of your information is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to obtain resources that help enhance and improve its products and services for customers.
6.4 If there is a need 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 group company if such a transaction occurs, including asset transfers or sales, mergers, restructuring, consolidations, or bankruptcy proceedings involving the Company or any group business.
7. Cookies and Services from Third Parties
We may use third-party services, such as advertising and analytics providers, on our website. These companies may also use cookies or similar tracking technologies.
7.2 Cookies are small text files stored on your device when you visit our website. We use them to understand your preferences and browsing behaviour, enhance your experience, remember your settings, and personalise the products and services we offer. Cookies also help us gather analytics and usage statistics.
7.3 We use two types of cookies on our website. Session cookies are temporary and remain on your device only while your browser is open. Once you close your browser, they're automatically deleted. Persistent cookies work differently—they stay on your device even after you close your browser. We use these to recognize you as a returning user and to help you access the website more easily on your next visit.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for accessing the features and services you've requested and for navigating our website. We use them to deliver the information, products, and services you ask for.
They're required for your device to download and stream data, allowing you to navigate the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm you're logged in to the site. They are automatically deleted when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognize you when you visit our site and remember your preferences.
Additional Information
They remain valid until the expiry date and persist even after you close your browser.
The type of cookie
Cookies for performance
Scope
Cookies help us gather performance data and improve your experience on our website. They also enable us to analyse how our site is being used.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. They can be removed when you close your browser. Some cookies remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, adjust your browser settings. Below are links to help you configure this for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, be aware that certain functions or the entire Website's features may not work as expected if this occurs.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
The Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for such longer periods as required or permitted by applicable law, regulations, and policies.
We'll share your information with third-party trading platforms for 12 months. If you consent, we'll continue sharing your data for another 12 months.
We regularly review the Personal Data we retain to ensure it's still necessary.
9. International Transfers
Your personal information may be transferred to other countries, including to third countries or international organisations. The Company takes all necessary measures to protect your personal data and ensure that data 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 international organisation that the EU Commission has determined provides adequate 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").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was completed in accordance with the standard data protection clauses approved by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide details about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. For more information, email: support@royal-sparforge.com
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect your Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that your Personal Data will be kept secure without any issues. We are not responsible for indirect, incidental, or consequential damages that may result from the use or disclosure of your Personal Data. This includes, but is not limited to, Personal Data being disclosed due to transmission errors, unauthorised access by third parties, or any other circumstances beyond our control.
10.3 If we're required by law or circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we must comply. However, we cannot guarantee the security measures these third parties apply to your data once it's transferred.
Personal Data cannot be transferred over the internet with complete safety. The Company cannot guarantee the security of Personal Data you transmit to us through the internet.
11. Hyperlinks to Third Party Websites
Our website may include links to third-party sites and applications that operate independently of the Company. We do not supervise these external platforms and are not responsible for how they collect or process your Personal Data. This Policy does not apply to activities conducted through those third-party sites or applications.
11.2 When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you review what Personal Data you share with them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If we make changes, we will notify you by posting the updated Policy on our website.
12.2 Additionally, when we make significant changes to this Policy, we will attempt to notify you through methods we consider appropriate and will publish an announcement on our website.
12.3 Any amendments, unless explicitly specified otherwise, will take effect following the publication of the revised Policy.
13. Your Rights
You have the right to ask us to verify that your Personal Data is accurate, correct any errors, and delete information we no longer need. You may also limit how we process your personal information.
If you are an EEA resident, please refer to this page for your data protection rights. You can exercise these rights regarding any personal information you've shared with us. To request to exercise your rights, please email the address below.
13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. If accurate, you can access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed at no charge, though a reasonable fee may apply for additional copies. Data will be made available electronically upon request. Your right to access Personal Data cannot override the rights and freedoms of others. If fulfilling your request would harm another person's rights or freedoms, the Company may refuse or limit its response to your request.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete or inaccurate Personal Data about you be corrected, based on the purpose of processing.
13.5 Right to Erasure The following reasons are applicable: (a) Personal Data are no longer needed 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, for reasons specific to your situation, to the processing of Personal Data about yourself based on legitimate interests pursued by Us or a third party; (e) Personal Data are processed unlawfully; or (f) Personal Data must be removed to comply with a legal obligation. This right does not apply when processing is necessary (a) to fulfil an obligation required under European Union law or Member State 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 can request that the Company limit how your Personal Data is processed. Once a restriction is requested, your Personal Data may only be retained if you provide consent, or if it is necessary to establish, exercise, or defend legal rights—either your own or those of another individual—or where there is a significant public interest reason recognised by the European Union or a Member State.
13.7 Right to data portability If your Personal Data is processed by an automated system based on your consent or a contract you're party to, you have the legal right to review and request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. The exercise of your right to data portability does not affect your erasure rights. This right does not interfere with the rights or freedoms of others.
13.8 Right to challenge You have the right to object to any use of your Personal Data based on legitimate interests pursued by the Company or a third party at any time. This right applies regardless of whether the processing involves profiling based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue only if you can show that our interests are outweighed by your rights, freedoms, or interests, or by the need to exercise, establish, or defend legal rights. For direct marketing, you have the right to object to the processing of your Personal Data at any time.
13.9 Right to revoke consent You may withdraw your consent for us to process your Personal Data at any time. Withdrawing consent will not affect the validity of any processing that was carried out with your consent before the withdrawal. You have the right to lodge a complaint with your supervisory authority. You may also submit an appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals regarding Personal Data processing within the European Union. The laws of the European Union and its Member States may limit your rights concerning your Personal Data, as described in this section 13.
We'll provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended to up to two months, depending on the complexity and volume of requests. If an extension is necessary, we'll notify you within one month of receiving your request, along with the reasons for the delay.
13.11 As long as it does not contradict section 13 of the law, we will provide the information you request under your section 13 rights at no cost. If your request is unjustified or excessive, particularly if repeated, we may charge a reasonable fee to cover our administrative costs for providing the information or taking the requested action. We may also decline to proceed.
13.12 If we have any doubts about the identity of the person who submitted your request, we may ask them to provide reasonable means of identifying themselves.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Royal Sparforge 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@royal-sparforge.com