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 Cove Schatzholm (the "Website").
We want you to have the information needed 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 where specific details are required, we'll provide them at the relevant time. We're also happy to answer any questions you have about applicable legal limitations.
1. The Scope
This policy explains what Personal Data the Company collects about individuals, and how that data is processed, shared with third parties, and secured.
1.2 This Policy applies to 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 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 and are not designed for anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we knowingly permit them to use our services. If we become aware that we hold information relating to a child, 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. We may also request personal data from you in certain circumstances.
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 restrict your access to the website.
4. What Personal Data We Collect
4.1 This includes information about 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 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 a 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 described 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:
- By submitting personal data through this website, you consent to it being shared with a third-party trading platform for that purpose.
- 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 about the processing carried out to protect legitimate interests, please contact us by email.
5.4 The following outlines the purposes and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
If requested, 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 necessary to address any questions you may have about the Services.
Processing is necessary to support the legitimate interests of the Company or a third party.
Personal data is processed to meet any 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, including crash reports and malfunction data collected in connection with the Services.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.
5. To stop fraud and misuse of Our Services.
Processing data is necessary 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 functions, business development, strategic decision-making, and oversight mechanisms.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical methods, including statistical techniques, to inform decisions across different areas.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant 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 required to serve 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, as well as companies that analyse user experience and IP address data.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will pass the Personal Data you have provided to us to those platforms. Your Personal Data will then be subject to their respective privacy policies. 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 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 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 entity within the group.
7. Cookies and Services from Third Parties
7.1 We may work with third-party services — such as advertisers and analytics providers — that operate on our website. These third parties may also use cookies or similar tracking technologies.
7.2 Cookies are small text files placed on your device when you visit the website. They collect information about your browsing habits and preferences 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 help the website 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 required to give you access to the features you've requested and to help you navigate our website. They enable your device to download and stream data, allowing you to use the site's features and return to pages you've previously visited.
Additional Information
Session cookies collect personal data such as your username and last login date to verify you are logged in. They are deleted automatically when you close your browser.
The type of cookie
Functionality Cookies
Scope
Cookies recognise you each time you visit our site and save your settings and preferences.
Additional Information
These cookies persist until their expiry date and are retained 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 associated with any identifiable individual. Some cookies are removed when you close your browser; others remain valid indefinitely.
7.4 If cookies are blocked or removed, you'll need to adjust your browser settings. The links below walk you through the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note that disabling cookies may cause some or all Website features to work differently than expected.
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 laws, regulations, or orders.
8.2 We will share your information with third-party trading platforms for 12 months. If you consent to this, 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 your personal data and ensure you can effectively assert your rights and access appropriate legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area):
- Transfer 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, in accordance with Article 46(2)(a).
- This transfer was made in accordance with standard contractual clauses adopted by the European Commission under Article 46(2)(c) of the GDPR.
9.3 We 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@coveschatzholm.com
10. Security of Personal Data
We have taken 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 at all times or free from error. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including disclosure resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
In some circumstances, we may be legally or otherwise obligated to disclose your personal data to third parties, including public authorities. In those situations, we have no control over how those third parties handle or secure 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 Our 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 those sites or applications.
Before accessing or using any third-party websites or apps, we recommend reading their privacy policies. Be mindful of what personal data you share with them.
12. Modifications to This Policy
This Policy may be updated at any time. If changes are made, we will notify you by posting the updated Policy on our website.
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 verification of the accuracy of Personal Data we hold about you, correction of any errors, and deletion of Personal Data we no longer require. You may also restrict the types of processing applied to your Personal Data.
If you are an EEA resident, please refer to this page for information about 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 upon request and may charge a reasonable fee for additional copies. This right must not infringe on the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, 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 may also request that incomplete Personal Data be corrected, taking into account 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 required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no remaining legal basis for processing; (c) you object, on grounds specific to your situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to fulfil a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal 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 may ask the Company to 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 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 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 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 the legitimate interests of the Company or a third party, including profiling based on those interests. Where such an objection is raised, we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal rights. 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 your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You have the right to lodge a complaint with your relevant supervisory authority. Within the European Union, you may also lodge a complaint with a supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that EU and member state laws may limit the rights described in this section 13.
We will provide the information you request under section 13 of this agreement within one month of receiving your request. If the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
Subject to section 13 of the law, information provided in response to a request made under your section 13 rights will be supplied at no cost. Where a request is unjustified or excessive — in particular where requests are repeated — we may charge a reasonable fee to recover the administrative costs of providing the information or carrying out the requested action. We may also decline to act on such a request.
13.12 If we have doubts about the identity of the person submitting a request, we may ask that person to provide reasonable proof of identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Cove Schatzholm 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@coveschatzholm.com