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 Bold Accrudency (the "Website").
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods to keep you appropriately informed, and where specific details are required, we will provide them at the relevant time. We are also happy to address any questions you have regarding applicable legal limitations.
1. The Scope
This policy explains what Personal Data the Company collects about natural individuals, how it processes and secures that data, and the circumstances under which it is shared with third parties.
This Policy covers 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 For the purposes of 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 platform, and we do not knowingly collect information from minors. If we become aware that we hold data belonging to a person under 18, 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 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 restrict your access to the website.
4. What Personal Data We Collect
4.1 This includes 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 non-personal 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 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 valid 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 its processing and transfer to a third-party trading platform.
- 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 on the processing carried out to protect legitimate interests, please contact us by email.
5.4 The following outlines the reasons and legal bases on which we may use the information you provide to us:
Scope
Legal Basis
At your request, we may collect and share your personal data with third-party companies to facilitate 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 required to address any questions you may have about the Services.
Processing of personal data may be required to serve the legitimate interests of the Company or a third party.
Personal data is processed to meet 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. This includes crash reports and malfunction data collected in connection with the Services.
Processing of personal data may also be required to serve the legitimate interests of the Company or a 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 relevant third party.
6. To carry out and manage activities required to operate Our Services
This includes back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing must serve the legitimate interests of the Company or a third party.
We use statistical and other analytical techniques to support decision-making across a range of issues.
Processing requires the legitimate interests of the Company or a third party to be served.
8. To protect our assets, rights, and interests, as well as 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
The Company may also share personal data with third-party service providers, including hosting and storage providers, IP address data handlers, and user experience analytics firms.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us directly to those platforms. Your Personal Data will then be governed by their respective privacy policies. Please note 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 enhance and improve the products and services provided to its 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 competent authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of company assets — or as part of any 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 service providers — such as advertisers and analytics companies — who operate on our website and may use cookies or similar 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 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 your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you pick up where you left off.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are required to give you access to the features you request and to help you navigate our website. They enable your device to download and stream data, access the information, products, and services you've asked for, and return to pages you've previously visited.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify your session. They are automatically deleted when you close your browser.
The type of cookie
Functionality Cookies
Scope
Cookies help us recognize you when you visit our site and remember your preferences.
Additional Information
These cookies persist until their expiry date and remain stored 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 conduct analysis that helps us improve your experience.
Additional Information
Cookies store anonymous data that is not linked to any identifiable individual. Session cookies are removed when you close your browser, while others remain valid indefinitely.
7.4 If cookies are blocked or removed, you'll need to adjust your browser settings. The links below guide 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 not function as intended.
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 longer periods as permitted by applicable law, regulation, or order.
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
Your personal information may be transferred to other countries, including to third-country recipients or international organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the ability to exercise your rights and access effective legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).
- Transfers to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data under 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 EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company 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@boldaccrudency.com
10. Security of Personal Data
We have implemented appropriate organizational 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 and error-free at all times. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
In certain circumstances, we may be legally or otherwise obligated to share your personal data with 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 cannot be guaranteed to be fully secure. The Company cannot ensure the security of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 This website contains 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.
11.2 When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Exercise caution when sharing any Personal Data with them.
12. Modifications to This Policy
This Policy may be updated at any time. If changes are made, the revised Policy will be posted 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 verification of the accuracy of Personal Data collected about you, to have any inaccuracies corrected, and to request deletion of Personal Data we no longer require. You may also restrict the types or scope of processing applied to your personal data.
If you are a resident of the EEA, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, send a written request to the email address provided below.
13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If confirmed, you may access your 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 the data electronically, it will be provided in that format. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request is detrimental to the rights or freedoms of another person, the Company may refuse or limit its compliance with that request.
13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You may also request that incomplete Personal Data be rectified, 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 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 specific situation, to the processing of Personal Data about you that is based on legitimate interests pursued by us or 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 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 requested, 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 ground 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 that 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 any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This right also applies to profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where the processing relates to the establishment, exercise, or defence of legal claims, we may continue processing despite your objection. 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 to process your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out before the withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, you may submit a complaint to 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 are entitled to 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 inform you of any extension, along with the reasons, within one month of receiving your request.
Subject to Section 13 of the law, any information you request under your Section 13 rights will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of fulfilling the request or processing the action sought. We may also decline to act on such requests.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that individual to provide appropriate verification of their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Bold Accrudency 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@boldaccrudency.com