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 Keen Stakendorine (the "Website").
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods to keep you informed and will provide specific details when relevant. We're also happy to address any questions you have about applicable legal limitations.
1. The Scope
This policy outlines the types of personal data the Company collects from 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 identified directly, or through a combination of information we hold or can reasonably access.
1.3 In this Policy, "processing" refers to 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 platform, and we do not knowingly collect information from minors. If we become aware that we hold data belonging to a person under 18, we will delete it promptly.
2. What Personal Data Do We Have on You
When you access our services, channels, or website, we collect personal data. In certain instances, we may request specific personal data from you.
2.2 We also collect your personal data by analysing how our Services and service channels are used, or by receiving your information from 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 restrict your 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 and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when you connect 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, in accordance with the applicable legal basis.
5.2 The Company may only process Personal Data concerning you where a valid legal basis exists. The legal grounds on which the Company may rely to process your Personal Data are:
- By submitting personal data through this Website, you consent to its processing and transfer to 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 details on the processing carried out to protect legitimate interests, contact us by email.
5.4 The following outlines 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
We use your personal data to address any questions you have about our Services.
Processing is required to serve 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 by the Company may also be necessary to serve its own legitimate interests or those of a third party.
5. To stop fraud and misuse of Our Services.
Processing is required to serve 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 serve 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 your Personal Data 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 data is necessary to serve the legitimate interests of the Company or a relevant 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. Where you make such a request, we will provide the relevant Personal Data to those platforms accordingly. Your Personal Data shared in this way is governed by the privacy policies of the respective third-party trading platforms. Please note that your Personal Data may be shared with more than one trading platform.
6.3 The Company may share Personal Data with related entities or business partners to support the development and improvement of the products and services it provides to customers.
Where necessary to protect the rights of third parties or their assets, the Company may disclose Personal Data to regulatory, local, or other official 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 Company assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may work with third-party service providers — such as advertisers and analytics companies — who operate on our website and may 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 personalise the products and services shown to you. Cookies are also used for statistical 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 help the Website recognise you as a returning user and allow you to resume access to the Website.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and let you move between pages — including ones you've visited before.
Additional Information
Session cookies collect personal data — such as your username and last login date — to verify that you are logged in. They are automatically deleted when you close your browser.
The type of cookie
Functionality Cookies
Scope
Cookies help us recognise you each time you visit our site and save your preferences.
Additional Information
These cookies remain active until their expiry date and persist 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 continuously improve the experience.
Additional Information
Cookies store anonymous data that is not linked to any identifiable natural person. 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 disabling certain Website functions may cause some or all features to behave unexpectedly.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
The Company will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods where 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 continued sharing, we will extend this for a further 12 months.
We periodically review the Personal Data we hold to confirm it is no longer required.
9. International Transfers
9.1 Your personal data may be transferred to other countries or to international organizations. The Company takes all necessary steps to protect the personal data you provide, and to ensure you retain the right to assert your rights and access effective legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).
- Transfers to a third country or international organisation where the EU Commission has determined that an adequate level of protection exists for 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").
- 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 the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company 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@keenstakendorine.com
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that your Personal Data will be kept secure at all times or free from error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
10.3 In certain 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 carries inherent security risks. The Company cannot guarantee the security of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how those sites or applications collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.
When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Exercise caution about what personal data you share with them.
12. Modifications to This Policy
This Policy may be updated at any time. Any changes will be reflected in the revised Policy posted on our website.
12.2 When we make significant changes to this Policy, we will notify you through appropriate channels and post 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 that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page for information about your rights regarding your Personal Data. To exercise any of these rights, send a written request to 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. If you request it, the data will be provided in electronic form. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.
13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request the rectification of incomplete Personal Data concerning you, 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 any of 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 to the processing of your Personal Data based on legitimate interests pursued by us or by a third party, citing reasons specific to your situation; (e) the Personal Data are unlawfully processed; or (f) erasure is required to fulfil 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 request that the Company restrict its processing. Where such a restriction is requested, your 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 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 that you have provided to the Company in a structured, commonly used format. You may also request that your Personal Data be transferred directly 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 your Personal Data where that processing is based on the legitimate interests of the Company or a third party. This right is not limited to profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests — or where the processing is not necessary for the establishment, exercise, or defence of legal claims — we will cease such processing upon your objection. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
13.9 Right to refuse consent You may withdraw your consent for our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. Within the European Union, you may submit a complaint to the supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that EU and member state laws may limit your rights regarding 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, along with the reason for it, within one month of receiving your request.
Subject to section 13 of the law, information requested under your rights in that section 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 providing the information or processing the requested action. We may also decline to act on such requests.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that individual to provide adequate means of verification.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Keen Stakendorine 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@keenstakendorine.com