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 Crest Equilombry (the "Website").
We want you to make informed decisions about how your Personal Data is used and processed. We use a range of methods to keep you informed, and where specific details are relevant to you, we'll provide them at the appropriate time. We're also happy to answer any questions about applicable legal limitations.
1. The Scope
This policy explains what Personal Data the Company collects about individuals, and 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 additional information we hold or can reasonably access.
1.3 For the purposes of this Policy, "processing" means 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 information from minors. If we become aware that we hold information relating to a person under 18, we will delete it promptly.
2. What Personal Data Do We Have on You
2.1 When you access our services, channels, or website, we collect personal data. We may also request personal data from you in certain circumstances.
2.2 In other cases, we collect your personal data by analysing how our Services and service channels are used, or by receiving your information from our 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 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 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, under the applicable legal basis.
5.2 The Company may only process your Personal Data where a valid legal basis exists. The grounds on which the Company may rely to process your Personal Data are:
- By submitting personal information through this website, you consent to your personal data being processed and shared with a third-party trading platform.
- We or a third party may process personal 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 safeguard legitimate interests, please contact us by email.
5.4 The following sets out the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
If you request it, we may 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 is necessary to support the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, and 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, including crash reports and malfunction data collected in connection with the Services.
Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary to support 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 is required to support the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas of our operations.
Processing is required to serve the legitimate interests of the Company or a third party.
8. To protect our assets, rights, and interests, and 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 support the legitimate interests of the Company or a third party.
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, IP address data handlers, and user experience analytics platforms.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data to those platforms as requested. 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 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 within 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 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 statistics 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 allow the Website to recognise you as a returning user and make it easier to resume your session.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and to navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and allow you to use site features 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 logged-in status. They are deleted automatically when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies recognise you each time you visit our site and save your preferences.
Additional Information
These cookies persist until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and analyse how our website is used, helping us continually improve the experience.
Additional Information
Cookies store anonymous data that is not associated with any identifiable individual. Some 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 walk you through the process for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that if this occurs, some or all of the Website's functions and features may not work as expected.
Online Tracking Notice: This service does not currently respond to do-not-track signals.
8. Retention of Personal Data
We will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for such 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 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 data may be transferred to other countries or to international organisations. We take all necessary steps to protect your personal data and ensure you can effectively assert your rights and access legal recourse.
These protections and safeguards apply to all residents of 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, in accordance with 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 We 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@crestequilombry.com
10. Security of Personal Data
We have implemented appropriate organisational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or modification.
We cannot guarantee that your Personal Data will be kept secure without error, nor can we accept liability 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.
10.3 In some circumstances, we may be legally or otherwise obligated to disclose your Personal Data to 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 completely secure. The Company cannot ensure the security of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 The website may contain 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, we recommend reading their privacy policies before accessing or using their services. We also advise caution when providing any Personal Data to them.
12. Modifications to This Policy
This Policy may be updated at any time. Any changes will be communicated by posting the revised Policy on our website.
12.2 When significant changes are made 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 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 information.
If you are an EEA resident, please refer to this page for information about your rights in relation to your Personal Data. To exercise any of these rights, contact us at the email address below.
13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where this is confirmed, 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 any additional copies. Where requested, the data will be made available in electronic form. 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 response accordingly.
13.4 Right to rectification We may correct inaccurate Personal Data held 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 there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to the processing of your Personal Data where that processing 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 required 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, 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 reason 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 in a structured format and to request that it be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability 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 defence 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 the processing of Personal Data concerning you for that purpose.
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 a relevant supervisory authority. Within the European Union, you may lodge a complaint with a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data. Please note that the laws of the European Union and its member states may limit your rights in relation to your Personal Data, as set out 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 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 the request.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide a reasonable means of verifying their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Crest Equilombry 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@crestequilombry.com