Privacy Policy

1. The Scope

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

1.2 This Policy covers 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 additional information we hold or can access.

1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data. This includes managing, organising, and storing Personal Data.

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 any person younger than 18 years old. We do not knowingly permit such individuals to use our services. If we become aware of any information relating to children, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 When you access the service and channels or visit our website, we collect Personal Data. In certain instances, we may request your Personal Data.

2.2 In other instances, 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. However, in certain circumstances, you may need to supply us with personal data. Failure to do so could prevent us from offering the Services or limit your access to the website.

4. What Personal Data We Collect

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 provide to us at your own discretion when you connect with a third-party online trading platform through us.

4.4 Personal information you provide specifically to third-party platforms to facilitate trading: this information 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 outlined in this section and in accordance with the applicable legal basis.

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

5.4 Below is a list of reasons and legal grounds for which we may use the information you provide us with:

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, and user experience analysis.

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 Personal Data you have given us to these third-party platforms. The use of your Personal Data will be 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 enables the Company to access the resources necessary to enhance and improve the products and services it provides to its customers.

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

6.5 We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group if such a transaction occurs (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 stored on your device each time you visit or use the website. They collect information about your preferences and browsing behaviour to enhance your experience, remember your settings and tailor the products and services that may interest 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 for a short time before you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after you close your browser. They help the Website recognise you as a returning user and allow you to revisit the site.

7.5 However, be aware that some or all of the Website's functions and features may not work as expected if this occurs.

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 fulfill the processing purposes described in this Policy, or for longer periods as permitted by law, regulations, policies, and applicable orders.

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

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

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country or to international organisations). The Company takes all necessary steps to safeguard the personal data you provide and ensure that data users have the ability to assert their rights and access effective legal recourse.

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

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical safeguards to protect Personal Data. This includes measures to prevent accidental or unlawful destruction, loss, or alteration of Personal Data.

We cannot guarantee that your Personal Data will remain completely secure or error-free. We are also not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure caused by transmission errors, unauthorised third-party access, or any other circumstances beyond our control.

10.3 If we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In such circumstances, we cannot control the security measures applied to 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 guarantee the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party websites and applications are provided on the site. These applications and websites are not under the supervision of the Company. 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 them. We also suggest you review these policies before providing any Personal Data.

12. Modifications to This Policy

12.1 This Policy may be updated from time to time. If we make changes to this Policy, we will notify you by posting the revised version on our website.

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

12.3 Any amendments, unless expressly stated otherwise, will take effect upon publication of the updated Policy.

13. Your Rights

13.1 You are entitled to request that we verify the accuracy of the Personal Data we hold about you, rectify any inaccuracies, and delete any Personal Data that is no longer required. You may also restrict the types of processing carried out on your personal information.

13.2 If you are a resident of the EEA, please refer to this page. You have the following rights regarding the Personal Data you provide. To exercise these rights, please email the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If it is, you are able to access your Personal Data. The Company will supply 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 request it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to 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 is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer required for the purposes for which they were collected or processed; (b) You withdraw consent and there is no other legal basis for processing; (c) You object at any time, based on reasons specific to your situation, to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are being processed unlawfully; or (f) Personal Data must be erased to comply with a legal obligation to which the company is subject. 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.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data. If you request such a restriction, your Personal Data may only be retained with your consent, or where necessary to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of substantial 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 a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used and machine-readable format. You may 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 to erasure. The right to data portability does not adversely affect the rights and freedoms of others.

13.8 Right to challenge You have the right to object at any time to any use of your Personal Data based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data that override your rights, freedoms, or interests—or are necessary for the establishment, exercise, or defence of legal claims—we may continue processing. Otherwise, we will cease processing. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning 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 of any processing that relied on your consent before it was withdrawn. You have the right to lodge a complaint with your supervisory authority. You may appeal to a supervisory authority established by an EU Member State to protect individuals' fundamental rights regarding the processing of Personal Data within the European Union. EU and Member State laws may limit your rights in relation to your Personal Data, as outlined in this section 13.

13.10 We will provide you with the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests. Should an extension be required, we will notify you within one month of receiving your request and explain the reasons for the delay.

13.11 As long as it does not conflict with the provisions of section 13 of the law, information you request under your rights in section 13 will be provided free of charge. If your request is unfounded or excessive, particularly if it is repetitive, we may charge a reasonable fee to cover administrative costs for 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 them to provide reasonable means of identification.