Privacy Policy

1. The Scope

This policy explains what Personal Data the Company collects about individuals, how that data is processed, shared with third parties, and kept secure.

This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly, or through a combination of additional information 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 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 personal information relating to a person under 18, we will delete it promptly.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect personal data. In certain instances, we may request specific personal data from you.

2.2 We also 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 required to provide us with any personal data. However, withholding it may prevent us from delivering the Services or limit your access to the website.

4. What Personal Data We Collect

The information collected is not personal 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 connecting with a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade 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 on how we process data to protect legitimate interests, contact us by email.

5.4 Below is a list of the reasons and legal grounds on which we may use 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 IP address information and user experience data.

6.2 You may also request that we share your Personal Data with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms. Your Personal Data shared in this way is governed by the privacy policies of the respective third parties. 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 enhance and improve 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 relevant authorities.

We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in connection with a transaction such as the transfer or sale of company assets, a merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may engage third-party services, such as advertising providers and analytics companies, on our website. These third parties may also use cookies or similar technologies.

7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences 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 analytics purposes.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help restore your previous session.

Please note that disabling cookies may affect the functionality of certain features or the Website as a whole.

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 regulatory order.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, 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

Your personal information may be transferred to other countries or to international organisations. We take all necessary steps to protect your personal data and ensure you can effectively assert your rights and access legal recourse.

9.3 We can provide details on the security measures used to protect your Personal Data when it is transferred to third-party countries or international organisations. To request this information, email: support@steadybarterolden.com

10. Security of Personal Data

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 intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.

10.3 In some 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 carries inherent security risks. 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 contain links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

Before visiting any third-party website or app, we recommend reading their privacy policy. You should also carefully consider what personal data you share with them.

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 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 may request that we verify the accuracy of the personal data we hold about you, 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 reside in the EEA, 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 The Company can verify the accuracy of Personal Data being processed about you. Where this is confirmed, 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 to access Personal Data 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 or limit its response accordingly.

13.4 Right to rectification We may correct any inaccurate Personal Data we hold about you. You have the right to request that incomplete Personal Data relating to you be completed, having regard to 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, on grounds relating to your particular situation, to processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data have been unlawfully processed; or (f) erasure is required 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 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 request that the Company restrict its processing. Where such 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 where there is a 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 your consent or a contract to which you are a party, you have the right to receive your Personal Data in a structured, commonly used format and to request that it be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure, and it does not infringe the rights or freedoms of any other person.

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 rights, we may continue to process your Personal Data. 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 for Us processing Personal Data about you at any time. Withdrawing consent does not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, you may lodge a complaint with a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data. Please note that the laws of the European Union and its member states may limit your rights in relation to your Personal Data, as set out in this section 13.

We will provide the information you have requested under section 13 of this agreement within one month of receiving your request. If the nature or volume of requests requires it, this period may be extended by up to two months. 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 made available at no cost. Where a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, 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 verification.