Bold Accrudency

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

Last updated: 03.09.2026

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 needed, we'll provide them at the right time. We're also happy to address any questions you have about applicable legal limitations.

By using our Website, you confirm that you have read and agree to this Privacy Policy. For questions: support@boldaccrudency.com

1. The Scope

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

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 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 personal 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 also 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 granting you 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 not personal data 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 described in this section, in accordance with the applicable legal basis.

5.2 The Company may only process Personal Data concerning you 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 about the processing carried out to protect legitimate interests, contact us by email.

5.4 The following outlines the reasons 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 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 data is necessary to serve the legitimate interests of the Company or a relevant 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 this data is necessary to support the legitimate interests of the Company or a relevant third party.

5. To stop fraud and misuse of Our Services.

Processing is required 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 operations, business development, strategic decision-making, and oversight functions.

Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.

To make informed decisions, we use a range of analytical methods, including statistical analysis.

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, 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 compliance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.

Processing data is necessary to serve the legitimate interests of the Company or a relevant third party.

6. Transfer of Personal Data to Third Party

The Company may also share personal data with third-party service providers that support our operations, including hosting and storage providers, IP address data processors, and user experience analytics services.

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 to those platforms. Your Personal Data will then be governed by the privacy policies of the respective third parties. 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 enhance and improve the products and services provided to its 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, 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 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 parties — such as advertisers and analytics providers — who operate on our website and may use cookies or similar tracking technologies.

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 shown to you. Cookies are also used for statistical and analytics purposes.

Some cookies we use 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 recognize you as a returning user and help you resume access seamlessly.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are required to access the features you use and navigate our website. They enable your device to download and stream data, deliver the information, products, and services you request, and allow you to move between pages you have previously visited.

Additional Information

Cookies collect personal data — such as your username and last login date — to verify your active session. They are automatically deleted when you close your browser (session cookies).

The type of cookie

Functionality Cookies

Scope

Cookies help us recognize you when you visit our site and save your preferences.

Additional Information

These cookies remain active until their expiry date and persist even after the browser is closed.

The type of cookie

Cookies for performance

Scope

We use cookies to collect statistical data and analyze website performance, helping us continually improve your experience.

Additional Information

Cookies store anonymous data not linked to any identified or identifiable individual. Session cookies are removed when you close your browser. Other cookies remain valid indefinitely.

7.4 If cookies are blocked or removed, you will 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 certain functions may affect how some or all Website features perform.

Online Tracking Notice: This service does not currently recognize 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, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

We regularly review the Personal Data we hold to confirm it's no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries 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, as established 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 carried out 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 without error, nor can we be held liable for any indirect, 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.

In some cases, we may be legally or otherwise obligated to share your Personal Data with third parties, including public authorities. In such circumstances, 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 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 that are not under the Company's supervision. We are not responsible for how these sites or applications collect or process personal data. This Policy does not apply to actions taken through such sites or applications.

11.2 When visiting any third-party websites or apps, review 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. Any changes will be reflected in the updated Policy 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 explicitly stated otherwise, 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 your Personal Data we collect, to have any inaccuracies corrected, and to request deletion of any 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 details on your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. Where applicable, 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 requested, data will be made available in electronic format. 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 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, having regard to 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 no other legal basis for processing exists; (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 by a third party; (e) the Personal Data have been unlawfully processed; or (f) erasure is required to fulfill 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 such 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 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 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 defense of legal claims, we may continue to process your Personal Data despite your objection. Regarding direct marketing, you have the right to object at any time to processing of Personal Data concerning you for such purposes.

13.9 Right to Withdraw Consent You may withdraw your consent for Us processing Personal Data about you 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, this means any 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 law may limit the rights described in this section 13.

We will respond to your request for information under Section 13 of this agreement within one month of receipt. Where the nature or volume of requests requires it, this period may be extended by up to two months. You will be notified of any extension, along with the reasons, within one month of your original request.

Subject to Section 13 of the law, information requested under your Section 13 rights will be provided at no cost. 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 notifying you of the action taken. 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 person to provide suitable means of identification.

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