Privacy Policy

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects about 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 someone who can be identified directly, or through a combination of additional information we hold or can 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 allow such persons to use our services. If we learn 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 instances, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information 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, withholding it may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.2 The information we collect is not private information 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 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 trade: 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, in accordance with the applicable legal basis.

5.3 Contact us by email for more details on the processing necessary to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, including IP address information and analysis of user experiences.

6.2 You may also ask us to share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you give us to these third-party trading platforms. Their use of your Personal Data is governed by their own 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 access to the resources needed to enhance and improve the products and services it provides to its customers.

6.4 Where necessary to protect the rights or assets of third parties, 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 or buyers, or with lenders to the Company or any other company in the group, where such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), 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 similar technology.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services that may interest you. 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 for a short period and expire when you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the Website recognise you as a returning user and allow you to return to the site.

7.5 Please note that if this occurs, some or all of the Website's functions and features may not work as you expect.

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 fulfil 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 to share 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 a third country or an international organisation. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can assert their rights and access effective legal remedies.

9.3 The Company can provide details of the security measures used to safeguard your Personal Data transferred to third-party countries or international organisations. Email: support@sable-vermohold.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational 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. Nor can we be held accountable 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 due to transmission errors, unauthorised access by a third party or any other cause beyond our control.

10.3 Where required by legal obligations or other circumstances beyond our control, we may need to provide your Personal Data to third parties, such as public authorities. In these situations, we cannot control the level of security applied to your Personal Data by those third parties.

10.4 No method of transmitting data over the internet is completely secure. 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 contains links to third-party sites and applications. These sites and applications are not under the Company's control. We are not responsible for the collection or processing of Personal Data by them. This Policy does not apply to any actions taken through such sites or applications.

11.2 When you visit any third-party website or app, we recommend that you read its privacy policy before deciding to access or use it, and exercise caution before providing any Personal Data.

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 We may also make significant changes to this Policy. When we do, 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 once the revised Policy is published.

13. Your Rights

13.1 You may request that we verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer require. You may also restrict the scope and 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 in relation to your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, 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 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. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with it or limit the extent to which it does so.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (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 at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning 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 a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing 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 the processing of your Personal Data. Where you request such a restriction, the Personal Data may only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights of another natural person, or for reasons of substantial 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 consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company. You may request that your Personal Data be transmitted 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 does not adversely affect the rights and freedoms of others.

13.8 Right to object You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based on those legitimate interests. Where we can establish compelling legitimate grounds for the processing, we may continue to process your Personal Data unless you can demonstrate that your rights, freedoms, or interests override those grounds, or that the processing is required for the exercise, establishment, or defence of legal claims. In the case of direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw your consent for Us to process 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 file an appeal with a supervisory authority established by a member state to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. The laws of the European Union and Member States may restrict your rights concerning Personal Data relating to you, as set out in this section 13.

13.10 We will provide the information you request under section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two further months, depending on the nature and number of requests. We will inform you of any such extension, and the reasons for it, within one month of receiving your request.

13.11 Where not contrary to section 13 of the law, information requested under your section 13 rights will be provided free of charge. If a request is unfounded or excessive, in particular where it is repetitive, we may charge a reasonable fee to cover the administrative cost of providing the information or taking the action requested. 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.