Privacy Policy

1. The Scope

This policy describes the types of Personal Data the Company collects about natural individuals, how it processes that data, and how it is shared with third parties and kept secure.

This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through a combination of additional information we hold or are reasonably able to access.

1.3 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we permit them to use our services. Should we become aware that any such information has been collected, 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 circumstances, we may ask you to provide personal data directly.

2.2 In other cases, we collect your personal data by analysing how our Services and service channels are used, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

The information collected is not personal data and cannot be used to identify you.

4.3 Personal data we receive from you: any personal data you voluntarily 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.

For more information about 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:

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, as well as companies that analyse user experience and IP address information.

6.2 You may also request that we share specific personal data about you with third-party trading platforms. Where you make such a request, we will share the relevant personal data with those platforms accordingly. Your personal data shared in this way will be subject to the privacy policies of the receiving platforms. Please be aware that your personal data may be shared with more than one third-party 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.

6.4 Where necessary to protect the rights of third parties or their 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 advertisers and analytics companies, which may also use cookies or similar technologies on our website.

7.2 Cookies are small text files placed on your device each time you visit the website. They are used to collect information about your preferences and browsing habits in order to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytical purposes.

Some cookies used on this Website 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 the browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you pick up where you left off.

Please note that disabling cookies may affect the availability or functionality of certain Website features.

Online Tracking Notice: This service does not currently support do-not-track signals.

8. Retention of Personal Data

We 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, regulation, or order.

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 regularly 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 your personal data and ensure that you retain the right to assert your rights and access effective legal recourse.

9.3 The Company can provide details of the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@lucrenholm.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 your Personal Data will be kept secure without error, nor can 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.

10.3 Where we are subject 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 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 via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for the collection or processing of personal data by those sites or applications. This Policy does not apply to actions taken through them.

When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. You should also take care when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.

12.2 When we make significant changes 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 that we verify the accuracy of your personal data, correct any inaccuracies, and delete any personal data we no longer require. You may also restrict the types of processing applied to your personal data.

If you are a resident of the EEA, please refer to this page. These rights apply to the personal data you provide to us. To exercise any of these rights, please contact us at the email address below.

13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where this is the case, you have the right to 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 any additional copies. The right of access must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.

13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request the correction of incomplete Personal Data relating to you, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request 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 to the processing of your Personal Data based on legitimate interests pursued by Us or a third party, and no overriding legitimate grounds exist; (e) the Personal Data have been unlawfully processed; or (f) erasure is required 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 rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where a restriction is in place, 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 on grounds 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 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 your right to data portability does not affect your 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 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. Concerning 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 your consent prior to withdrawal. You have the right to lodge a complaint with a supervisory authority. Within the European Union, supervisory authorities are established by Member States to protect the fundamental rights of individuals in relation to the processing of Personal Data. Please note that EU and Member State law may limit the rights described in this section 13.

We will respond to requests made under the rights set out in 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. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information provided in response to a rights request will be supplied free of charge. Where a request is manifestly unfounded or excessive — in particular where requests are repetitive — we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may decline to act.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide suitable means of identification.