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 (referred to as "We", "Us", or "Our") 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 Vega Kapiture (the "Website").
We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods and procedures to keep you properly informed. Where we believe specific details are relevant to you, we will provide that information at the appropriate time. We are also happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy describes the types of Personal Data the Company collects about individuals and how it processes, secures, and shares that data with third parties.
1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly by combining that information with additional information we hold or can access.
1.3 The Policy defines "processing" as any operation that uses or collects Personal Data, including its management, organization, and storage.
1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly allow such persons to use our services. If we discover that we hold any information about a child, we will delete it as quickly as possible.
2. What Personal Data Do We Have on You
2.1 We collect Personal Data when you access our services and channels or visit our website. In certain cases, we may request your Personal Data directly.
2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving 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, withholding such data may prevent Us from delivering Our Services or granting you access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and your 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
4.2 The information we collect 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 you connect with a third party's online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to facilitate trades: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to serve their legitimate interests, such as improving Our Services or defending against legal claims.
- Processing must meet an obligation of law.
5.3 Contact us by email for more details on the processing necessary to protect the legitimate interests.
5.4 We may use the information you provide for the following reasons and legal grounds:
Scope
Legal Basis
To share your personal information with third parties at your request to access digital trading
If you request it, we may collect Personal Data from you to forward it to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
We use Personal Data to address any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. To comply with any legal obligation, or with administrative, judicial, or legal requirements, Personal Data is processed to meet applicable legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to operate Our Services
These include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar activities.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We apply various analytical methods, including statistical techniques, to inform our decisions on a range of issues.
Processing is necessary for the legitimate interests of the Company or a 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 related terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party providers that supply services to us, such as hosting and storage providers, IP address information, and 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 these third-party trading platforms. Use of your Personal Data is governed by 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 gives the Company the resources to enhance and improve the products and services it provides to its customers.
6.4 To protect the rights or assets of third parties, 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 within the group, in connection with such a transaction (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 We may use third-party services, such as advertising providers on our website or analytics companies. 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 collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and last only until you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the Website recognize you as a returning user and make it easier to return to the website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you request and to navigate our website. They deliver the information, products, and services you have asked us to provide.
They also allow your device to download and stream data, letting you move around the website, use its features, and return to pages you have visited before.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm that you are signed in to the site. These are deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you on each visit and remember your preferences.
Additional Information
They remain valid until the expiry date and stay saved even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on the site's performance and to help improve it. They also allow Us to analyze our website.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable person. Some cookies are deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, adjust your browser's settings. The links below explain the process for several of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, if this happens, please be aware that some or all of the Website's functions and features may not work as you expect.
Online Tracking Notice: This service does not currently respond to do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
8.2 We will share your personal data with third-party trading platforms for a period of 12 months. If you agree, we will continue to share your data for a further 12 months.
8.3 We regularly review the Personal Data we hold to confirm it is still needed.
9. International Transfers
9.1 Your personal data may be transferred to other countries, including third countries or international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has recognised as providing adequate protection of Personal Data transferred to it, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public authorities or bodies, in accordance with Article 46(2)(a)
- The transfer was carried out in compliance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 Upon request, the Company can provide information about the security measures used to protect your Personal Data transferred to third-party countries or international organisations. Email us at: support@vega-kapiture.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but 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 We may be required to disclose your Personal Data to third parties, such as public authorities, where legal or other obligations beyond our control apply. In such cases, we cannot control the level of security those third parties apply to your Personal Data.
10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of Personal Data you transmit to Us through the internet.
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 the collection or processing of Personal Data by these sites or applications. This Policy does not apply to any actions taken through them.
11.2 Before you access or use any third-party website or app, we recommend reading their privacy policies and exercising caution before providing any Personal Data to them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If we make changes, We will notify you by posting the updated Policy on our website.
12.2 We will also notify you of significant changes to this Policy through methods we consider appropriate and by publishing an announcement on our website.
12.3 Unless otherwise stated, amendments take effect once the revised Policy is published.
13. Your Rights
13.1 You may request that we verify the accuracy of the Personal Data we hold about you, correct any errors, and delete any Personal Data we no longer require. You may also limit the scope and types of processing applied to your Personal Data.
13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the Personal Data you provide. To exercise them, send an email to the address below.
13.3 Access rights You may ask the Company to confirm whether your Personal Data is being processed. If it is, you may 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 you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfill it.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of the processing.
13.5 Right to Erasure The following grounds apply: (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 other legal basis for the processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by 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 the processing is necessary (a) to comply with a legal obligation that requires processing 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 you request such a restriction, your Personal Data may be retained only with your consent, or to establish, exercise, or defend legal claims, or to protect the rights of another natural person, or for reasons of significant 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 on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company. You may also request that your Personal Data be transferred directly from the Company 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 and freedoms of others.
13.8 Right to object You may 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, including profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing the Personal Data, we may continue to do so unless you can show that your rights, freedoms, or interests override them, or that the processing is necessary for the exercise, establishment, or defense of legal rights. In the case of direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
13.9 Right to withdraw consent You may withdraw your consent to Our processing of Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights concerning Personal Data about you, as set out in this section 13.
13.10 We will provide the information you request under your rights in section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and number of requests. We will notify you of any extension, along with the reasons, within one month of receiving your request.
13.11 Where permitted under section 13 of the law, the information you request under your section 13 rights will be provided free of charge. If a request is unfounded or excessive, particularly where it is repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or acting on the request. 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 them to provide reasonable proof of identity.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Vega Kapiture 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@vega-kapiture.com