Privacy Policy

We are committed to being transparent about how we collect and process your personal information:

We want you to be informed about how your Personal Data is used and processed. To support this, we use various methods to give you clear, relevant information at the right time. If specific details are needed, we'll provide them when appropriate. We're happy to answer any questions and clarify any limitations imposed by law. You can reach us by email at: info@falvisgainstead.com

Your personal data will only be used for the purposes set out in this Policy.

We may process your personal data for a number of purposes: to provide the website and connect you with third-party trading platforms (the 'Services'); to improve the site; to protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory or legal obligations; and to carry out administrative and business activities related to the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights regarding your Personal Data, you have access to meaningful tools designed to protect those rights.

To exercise your rights, contact us at any time to submit a request regarding your personal data. We can update or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We're committed to accommodating your requests.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This Policy describes the types of personal data the Company collects about natural persons and how that data is processed, shared with third parties, and secured.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for general audiences and are not directed at individuals under the age of 18. We do not knowingly seek or collect personal data from anyone under 18, and we do not knowingly permit such individuals to use our services. If we become aware that personal data has been collected from a minor, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. This may happen directly — when you provide it to us — or indirectly, through analysis of how you use our services or channels, or via information received from our third-party partners.

You are not required to share personal information with us. However, choosing not to do so may limit our ability to provide our Services or grant you access to the website.

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering our Services or granting you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes data about your online activity, traffic information (such as IP address, access dates, and access times), language settings, software crash logs, browser type, and device details. This information is non-personal and cannot be used to identify you.
Personal Data we receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal information provided 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 Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: When required to deliver our Services — for example, sharing data with payment processors, technology providers, or other service partners necessary to fulfill your requests. When required by law — including responses to lawful requests from regulatory authorities, courts, or government bodies. When necessary to protect our rights — including enforcing our Terms and Conditions, investigating potential fraud, or addressing security threats. With your consent — where you have explicitly agreed to the sharing of your personal data with a specific third party. In all cases, we share only the personal data necessary for the stated purpose. We do not sell your personal data to third parties. Where personal data is transferred to third parties acting on our behalf, we require those parties to handle your data in accordance with applicable data protection obligations and to implement appropriate security measures. If you have questions about how your personal data is shared, please contact us using the details provided in this policy.

We may share Personal Data with third-party service providers, including hosting and storage providers, for purposes such as infrastructure support and user experience analysis.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be transferred to those platforms, and its use will be governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with affiliated entities or business partners where this supports the development and improvement of our products and services.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data with prospective investors, buyers, or lenders — whether in connection with the Company or any entity within its group — in the event of a transaction, including the transfer or sale of assets, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Third-Party Services Our website uses cookies and services provided by third parties. These third parties may collect and process certain data about you when you use our site. By continuing to use our website, you acknowledge and accept the use of such cookies and third-party services. Third-party providers we work with may have their own privacy and cookie policies, which govern how they handle your data. We recommend reviewing those policies directly, as we do not control how third parties collect, store, or use your information. You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website or limit access to some features.

We may work with third-party services, such as advertising providers and analytics companies, that operate on our website. These third parties may also use cookies or similar technologies. Cookies are small text files placed on your device each time you visit the website. They are used to gather information about your preferences and browsing habits, improve your user experience, and personalise the products and services presented to you. Cookies are also used for statistical and analytics purposes. Some cookies we use are session cookies — temporary files downloaded to your device that 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 your session.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.
Your information will be shared with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

Transfers of Personal Information to a Third-Party Country or to an International Organisation

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organizational measures to safeguard it against unauthorized access, loss, misuse, alteration, or disclosure. While we implement appropriate security controls, no method of data transmission or storage is completely secure. We cannot guarantee absolute security, and you share personal data with us at your own risk. You are responsible for keeping your account credentials confidential. Do not share your password with anyone. If you suspect unauthorized access to your account, notify us immediately. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Once no longer needed, personal data is securely deleted or anonymized in accordance with our internal retention procedures. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by applicable obligations and within the timeframes prescribed. If you have questions about how we protect your personal data, contact us using the details provided in this policy.

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained 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, disclosure resulting from transmission errors, unauthorized third-party access, or other causes beyond our control.
Where legal or other obligations require it, we may be required to disclose Personal Data to third parties, such as public authorities. In such cases, we have no control over the security measures applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of any Personal Data you transmit to us through the internet.

11. Links to Third-Party Websites

Our website contains links to third-party websites and applications. These sites and apps 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 them.
Before accessing or using any third-party website or app, we recommend reading their privacy policy carefully. We also advise caution when sharing any Personal Data with them.

12. Modifications to this Policy We may update this Policy from time to time. When we do, the revised version will be posted on our website with an updated effective date. Continued use of our services after any changes take effect constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed of any updates.

Before visiting any third-party website or app, read their privacy policy carefully. Only provide your personal data to third parties after reviewing how it will be used.

13. Your rights with respect to your personal information You have certain rights regarding your personal information. These rights may be subject to limitations and exceptions under applicable law. Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal. You may have the right to: - Access the personal information we hold about you and receive a copy of it. - Request correction of any inaccurate or incomplete personal information. - Request deletion of your personal information in certain circumstances. - Object to or request restriction of our processing of your personal information. - Receive your personal information in a structured, commonly used, machine-readable format, and request that we transmit it to another controller where technically feasible. - Lodge a complaint with a relevant data protection authority if you believe we have not handled your personal information in accordance with applicable law. To exercise any of these rights, please contact us using the details provided in this policy. We may need to verify your identity before processing your request. We will respond within the timeframe required by applicable law. Please note that withholding certain personal information may prevent us from delivering our Services or granting you access to the website.

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also restrict the types or scope of processing applied to your personal data.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, submit your request by email to the address below.
Access rights
The Company can verify that Personal Data about you is being processed. If it is, you may request access to 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. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights or freedoms, the Company may decline or limit its response.
Right to rectification
The Company must correct inaccurate Personal Data. You may also request that incomplete Personal Data concerning you be completed, taking into account the purposes for which it is processed.
Right to erasure
This right applies where: (a) Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, on grounds specific to your situation, to processing based on legitimate interests pursued by us or a third party; (e) Personal Data has been unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.
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 request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure, nor does it affect the rights or freedoms of others.
Right to object
You have the right at any time to object to the 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 interests. Where we cannot demonstrate compelling legitimate grounds that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defense of legal claims, we will cease processing.
Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.
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 prior to that withdrawal.
You have the right to lodge a complaint with a competent supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals' fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit the rights described in this section 13 as they relate to Personal Data concerning you.
We will respond to requests made under section 13 within one month of receipt. Where necessary, due to the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, along with the reasons for it.
Unless otherwise restricted under section 13, information provided in response to your rights under section 13 will be supplied free of charge. Where requests are manifestly unfounded or excessive, in particular due to their repetitive nature, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person submitting a request, the Company may ask for additional information to confirm identity.