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 (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy. This Privacy Policy explains how we collect and store the information you provide through the Oak Kapithold website (the "Website").
We want you to be able to make informed decisions about how your Personal Data is used and processed. We use a range of methods and procedures to provide you with relevant information. Where we believe you need particular details, we will provide them at the appropriate time. We are happy to answer any questions you may have, subject to any legal restrictions.
1. The Scope
1.1 This policy explains what types of Personal Data the Company collects about individuals, how that data is processed, shared with third parties, kept secure, and otherwise handled.
1.2 This Policy relates to information concerning an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly or by combining other information that we hold or can access.
1.3 For the purposes of this Policy, "processing" means any activity involving the use or collection of Personal Data, including its handling, organisation, and storage.
1.4 Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect information from, or target, anyone under 18, nor do we knowingly permit them to use our services. If we become aware that we hold any information relating to a child, we will delete it as promptly as possible.
2. What Personal Data Do We Have on You
2.1 When you use our service and channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data.
2.2 In certain other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by obtaining your information from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You are not required to provide Us with any Personal Data. However, in some circumstances, if You choose not to do so, We may be unable to provide the Services or may prevent users from accessing the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity records and traffic data, including:
- 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 you 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, through us, with a third-party online trading platform.
4.4 Personal information you provide directly to third-party platforms to enable trading, including your full name, address, telephone 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 set out in this section and in line with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a lawful basis. The legal grounds on which the Company may process your Personal Data are as follows:
- 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 that we can pass it on to a third-party trading platform.
- The Company or a third party may need to process data where this is necessary for their legitimate interests, for example to improve Our Services or to establish, exercise or defend legal claims.
- Processing must meet an obligation of law.
5.3 Please contact us by email if you would like further information about the processing required to protect legitimate interests.
5.4 Set out below are the reasons we may use the information you provide, together with the legal bases for doing so:
Scope
Legal Basis
1. To share your personal information with third parties at your request so you can access digital trading
If you ask us to, we may collect Personal Data from you and pass it on 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 need Personal Data in order to deal with any queries you may have about the Services.
The Company’s legitimate interests, or those of a third party, require processing.
3. Personal Data is processed where necessary to comply with any legal, administrative or judicial obligation.
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, among other things, reports of crashes or other malfunctions that we collect in connection with the Services.
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required for the delivery of Our Services
This includes back-office operations, business development, strategic decision-making, oversight procedures, and related functions.
Processing is necessary for the Company’s legitimate interests or those of a third party.
7. To carry out analysis, including statistical analysis
We use a range of analytical techniques, including statistical methods, to support decision-making on various matters.
Processing is necessary for the Company’s legitimate interests or those of a third party.
8. To protect our assets, rights and interests, as well as those of third parties
We may process Personal Data where this is necessary to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions or policies.
Processing is necessary for the Company’s legitimate interests 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 service providers who support our operations, including hosting and storage providers, providers of IP address information, and providers of user experience analysis services.
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 to Us to those third-party trading platforms. Any use of your Personal Data will be governed by their privacy policies. Your Personal Data may be shared with more than one trading platform.
6.3 The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources it needs to develop and improve the products and services it provides to its customers.
6.4 Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
6.5 We may also share your Personal Data with prospective investors or purchasers, or with lenders to the Company or any other company within the group, where such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company in the group), or as part of any merger, restructuring, consolidation or insolvency involving the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may use third-party services, including providers that display advertising on our website and analytics companies. These organisations may also use cookies or similar technologies.
7.2 Cookies are small text files stored on your device whenever you visit or use the website. They help us understand your preferences and browsing behaviour so we can improve your experience, remember your settings, and tailor products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.
7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain there only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period after your browser is closed. They are used to help the Website recognise you as a returning user and allow you to return to the website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for you to access the features you have requested and move around our website. We use cookies to deliver the information, products and services you have asked for.
They are needed to allow your device to download and stream data. This enables you to browse the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect personal data, such as your username and the date of your most recent login, to confirm that you are signed in to the site. These cookies are deleted when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognise you whenever you visit our site and save your preferences.
Additional Information
They remain valid until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical information about the performance of the site and to help improve it. They also enable Us to analyse activity on our website.
Additional Information
Cookies store anonymous data that cannot be linked to an identified or identifiable individual. Some are deleted when you close your browser, while others remain valid for an indefinite period.
7.4 Cookies may be blocked or deleted. To block or remove cookies, you will need to change your browser settings. Below are links to guidance for some of the most widely used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please note that, should this occur, some or all of the Website’s functions and features may not operate as expected.
Online Tracking Notice: This service does not currently respond to do-not-track signals.
8. Retention of Personal Data
8.1 The Company will keep your Personal Data for as long as necessary to fulfil the purposes for which it is processed, as set out in this Policy, or for longer where permitted by applicable law, regulations, policies, or relevant orders.
8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
8.3 We review the Personal Data we hold on a regular basis to make sure it is no longer required.
9. International Transfers
9.1 Your personal information may be transferred to other countries (that is, your personal data may be sent to a third country or to international organisations). The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data subjects are able to exercise their rights and have access to effective legal remedies.
These protections and safeguards are available to everyone living in the EEA (European Economic Area):
- Transfer to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for Personal Data transferred to it under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR")
- The transfer is carried out under a legally binding and enforceable agreement between public bodies or authorities within the meaning of Article 46(2)(a)
- The transfer was carried out in accordance with standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide details of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Please email: support@oakkapithold.com
10. Security of Personal Data
10.1 We have put in place appropriate organisational and technical measures to protect Personal Data. These are designed to prevent the accidental or unlawful destruction, loss or alteration of Personal Data.
10.2 We cannot guarantee that your Personal Data will remain completely secure at all times, nor can we warrant that its protection will be free from error. We are also not liable for any indirect, incidental or consequential loss arising from the use or disclosure of Personal Data. This includes, but is not limited to, the disclosure of any Personal Data as a result of transmission errors, unauthorised access by a third party, or any other circumstances beyond our reasonable control.
10.3 Where we are subject to legal requirements or other circumstances outside our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these cases, we are unable to control how those third parties protect your Personal Data.
10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. 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 may include links to third-party websites and applications. These websites and applications are not under the Company's control or supervision. We are not responsible for how such websites or applications collect or process Personal Data. This Policy does not apply to any actions taken on or through those websites or applications.
11.2 Before accessing or using any third-party websites or apps, we recommend that you read their privacy policies. We also advise you to consider this before providing them with any Personal Data.
12. Modifications to This Policy
12.1 We may amend this Policy at any time. If we do so, we will notify you by publishing the updated Policy on our website.
12.2 In addition, if we make any significant changes to this Policy, we will seek to notify you using the methods we consider appropriate and will publish a notice on our website.
12.3 Unless stated otherwise, any changes will take effect once the updated Policy has been published.
13. Your Rights
13.1 You are entitled to ask us to confirm the accuracy of the Personal Data we hold about you, correct any errors, and erase any Personal Data we no longer require. You may also restrict the types of processing carried out in relation to your personal information.
13.2 If you are resident in the EEA, please refer to this page. You may exercise these rights in relation to the Personal Data you provide by emailing the address below.
13.3 Access rights The Company may verify the accuracy of the Personal Data it processes about you. Where this applies, you are entitled 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 further copies. If you request it, the data will be provided electronically. The right to access Personal Data must not adversely affect the rights and freedoms of others. Where a request would prejudice another person’s rights or freedoms, the Company may refuse the request or restrict the extent to which it can be fulfilled.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You also have the right to request the correction of any incomplete Personal Data relating to you, taking into account the purpose for which it is being processed.
13.5 Right to Erasure You may request the deletion of your Personal Data where: (a) the Personal Data are no longer needed for the purposes for which they were collected or otherwise processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object, on grounds relating to your particular circumstances, to the processing of your Personal Data where it is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been processed unlawfully; or (f) the Personal Data must be erased in order to comply with a legal obligation binding on the company. This right does not apply where processing is necessary: (a) to comply with a legal obligation requiring processing under European Union or Member State law; or (b) for the establishment, exercise or defence of legal claims.
13.6 Restrictions on processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request a restriction, the Personal Data may only be stored with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another individual, or where there is an important public interest recognised in 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 legal right to receive the Personal Data you have provided to the Company and to review it. You are also entitled to request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. This right does not prejudice the rights and freedoms of others.
13.8 Right to object You have the right at any time to object to the use of your Personal Data where processing is based on the legitimate interests pursued by the Company or a third party. This includes profiling where it is carried out on the basis of those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can show that your rights, freedoms or interests override those grounds, or where the processing is necessary for the establishment, exercise or defence of legal claims. In relation to direct marketing, you have the right to object at any time to the processing of your Personal Data.
13.9 Right to withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to make a complaint to the relevant supervisory authority. You may raise a complaint with a supervisory authority established by an EU Member State to protect individuals’ fundamental rights in connection with the processing of Personal Data within the European Union. The laws of the European Union and its Member States may restrict your rights in relation to your Personal Data, as set out in this section 13.
13.10 We will provide the information you request in accordance with the rights set out 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 of the request and the number of requests received. We will inform you of any extension within one month of receiving your request and explain the reasons for it.
13.11 Provided this does not conflict with the provisions of section 13 of the law, any information you request in exercising your rights under section 13 will be supplied free of charge. However, where a request is unfounded or excessive, particularly if it is repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also refuse to act.
13.12 If we have any doubts about the identity of the individual who submitted your request, we may ask the person making the request to provide reasonable proof of identity.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Oak Kapithold 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@oakkapithold.com