Privacy Policy

1. The Scope

1.1 This policy explains what Personal Data the Company collects about individuals, and how it processes, shares, and secures that data.

1.2 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 and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, and we do not knowingly permit such individuals to use our services. If we become aware that we have collected information relating to a minor, 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 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

The information collected is not personal in nature 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 to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading: this 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.

For more information on the processing carried out to safeguard legitimate interests, please contact us by email.

5.4 The following sets out the purposes 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 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 transfer the Personal Data you have provided to us 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 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 in the group, in connection with a transaction involving the transfer or sale of assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting 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 each time 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 help the Website recognise you as a returning user and allow you to resume access to the site.

Please note that disabling certain Website functions may cause some or all features to behave unexpectedly.

Online Tracking Notice: This service does not currently support do-not-track signals.

8. Retention of Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods as permitted by applicable law, regulation, or regulatory order.

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 periodically review the personal data we hold to determine whether it is still required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or shared with international organisations. We take all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.

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@keenmintonage.com

10. Security of Personal Data

We have implemented appropriate technical and organizational 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 disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

Where we are legally required or otherwise compelled by obligations beyond our control to disclose your Personal Data to third parties — such as public authorities — we cannot guarantee the security measures those parties apply to your 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 transmit to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 This 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 any actions taken through such sites or applications.

Before visiting any third-party website or app, read its privacy policy carefully. Exercise caution when sharing personal data with third parties.

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 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 your Personal Data, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types or scope of processing applied to your personal information.

If you are an EEA resident, please refer to this page for information on the rights available to you in relation to your Personal Data. To exercise any of these rights, submit a request by emailing the address below.

13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data and, if so, to access it. Upon request, the Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. The right to access Personal Data is subject to the rights and freedoms of others. Where fulfilling a request would be detrimental to the rights or freedoms of another individual, the Company may refuse or limit its response accordingly.

13.4 Right to rectification We may correct inaccurate Personal Data held about you. You have the right to 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 there is no other legal basis for processing; (c) you object to the processing of your Personal Data based on legitimate interests pursued by Us or by a third party, and no overriding legitimate grounds exist; (e) the Personal Data are 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 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 does not adversely affect the rights or freedoms of others.

13.8 Right to object You may object at any time to the processing of your Personal Data where that processing is based on the legitimate interests of the Company or a third party, including profiling based on those interests. If we 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 claims, we may continue to do so. Concerning direct marketing, you may object at any time to the processing of your Personal Data for that purpose.

13.9 Right to Withdraw Consent You may withdraw your consent to our processing of 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 lodge a complaint with the supervisory authority established by the applicable Member State to protect the fundamental rights of individuals 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 requests made under Section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to Section 13 of the law, information requested under your Section 13 rights will be provided free of charge. Where a request is unjustified or excessive — in particular where requests are repeated — we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act on such requests.

13.12 If we have reason to doubt the identity of the person submitting a request, we may ask that individual to provide reasonable verification of their identity.