Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects from natural individuals and how it processes, shares with third parties, secures, and otherwise handles it.

1.2 This Policy relates to information connected to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information that we have or can access.

1.3 The Policy defines "processing" as any process involving the use or collection of Personal Data. It includes the handling, structuring, and storage of Personal Data.

1.4 Our services are meant for general audiences and are not intended for anyone under the age of 18. We do not knowingly collect or seek information from any person younger than 18 years old. We do not knowingly permit such persons to use our services. If we become aware of any information about children, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 If you use the service and channels, or visit our website, we collect Personal Data. We may ask for your Personal Data in certain cases.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. In certain circumstances, however, you may choose not to provide Us with any Personal Data. This may prevent Us from offering the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.2 The information you collect 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 you connect with a third-party online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 Your Personal Data is processed by the company for the purposes set out in this section, and in line with the applicable legal basis.

5.3 Contact us by email for more details about the processing required to protect legitimate interests.

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 companies that provide services to us, such as hosting and storage providers, IP address information, as well as analysis of user experiences.

6.2 You may also ask us to share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you have given Us to those third-party trading platforms. The use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This can provide the Company with the resources needed to help enhance and improve the products and services it offers its customers.

6.4 Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 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, if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group) or as part of any merger, restructuring, consolidation or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, such as those providing advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits to improve user experience, remember your preferences, and personalise the products and services you may like. Cookies are also used for statistics and analytics.

7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period before you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for some time after you close your browser. They are used to help the Website identify you as a returning user and allow users to return to the website.

7.5 However, please note that certain or all Website functions and features may not work as you expect if this happens.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing Personal Data, as described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and orders.

8.2 We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we'll continue sharing your data for another 12 months.

8.3 We regularly review the Personal Data we hold to ensure it is no longer needed.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country or to international organizations). The Company takes all necessary steps to protect the Personal Data you provide and ensure that users are able to exercise their rights and access effective legal remedies.

9.3 The Company may provide information about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@thorn-kapstedham.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss or modification of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, however, and is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.

10.3 In the event of legal or other obligations beyond our control, we may be required to share your Personal Data with third parties, such as public authorities. In such situations, we cannot control the security provided for your Personal Data by those third parties.

10.4 Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you send to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party sites and applications are provided on the website. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.

11.2 When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use their apps. We also suggest that you share any Personal Data with them.

12. Modifications to This Policy

12.1 This Policy may be changed at any time. If we make changes to this Policy We will notify you by posting the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will seek to inform you using the methods we believe are appropriate and will publish an announcement on our website.

12.3 Any amendments, unless expressly specified, will take effect after the revised Policy is published.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights are available to you in relation to the information you provide as part of your Personal Data. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of the Personal Data being processed about you. If so, you are able to 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 any additional copies. The data will be made available electronically if you ask for it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to another person’s rights and freedoms or their rights, the Company can refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company has the right to rectify inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, for reasons specific to your situation, to the processing of your Personal Data based on legitimate interests pursued by Us or by a third party; (e) Personal Data are processed unlawfully; or (f) Personal Data must be erased to comply with the company's legal obligation. 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 can ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, it may only be retained with your consent or to establish, exercise or defend legal rights, to protect the rights of another natural person, or where there is a reason of significant public interest within the European Union or a Member State.

13.7 Right to data portability If processing is carried out through an automated system and is based on your consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company. You are also entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right of erasure. The right to data portability does not affect the rights or freedoms of any other person.

13.8 Right to challenge You have the right at any time to object to any use of Personal Data relating to you that is based on legitimate interests pursued by the Company or a third party. This right also applies to profiling based solely on those legitimate interests. If we are able to demonstrate compelling legitimate grounds for processing Personal Data, we may continue to do so unless you can show that your rights, freedoms, or interests override those grounds, or where processing is necessary for the establishment, exercise, or defence of legal claims. In relation to direct marketing, you have the right at any time to object to the processing of Personal Data relating to you.

13.9 Right to refuse consent You may withdraw your consent for Us to process your Personal Data at any time. This will not affect the legality or lawfulness of any processing carried out based on your consent before it was withdrawn. You are entitled to file a complaint with the authority that supervises you. You may also appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in this section 13.

13.10 We will provide the requested information in line with your rights under section 13 of this agreement within one month of receiving your request. This time frame may be extended by up to two months, if necessary, depending on the nature of the request as well as the number of requests. Within one month of receiving your request, we will notify you of any extension, along with the reasons.

13.11 Provided this is not contrary to the provisions of section 13 of the law, the information you request under your rights in section 13 will be provided free of cost. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative expenses of providing the information or communicating the action requested. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request We may ask the person making the request to provide reasonable proof of identity.