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 Lodestar Kapiton (the "Website").
We want you to have the information needed to make informed choices about how your Personal Data is used and processed. We use a range of methods to keep you informed, and where specific details are required, we will provide them at the relevant time. We are happy to answer any questions you may have about applicable legal limitations.
1. The Scope
This policy explains what Personal Data the Company collects about natural individuals, how it processes and secures that data, and how it is shared with third parties.
1.2 This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be recognised 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 them, and we do not knowingly collect information from persons under that age. If we become aware that we hold data relating to a child, 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 also request personal data from you directly.
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 third-party partners.
3. No Requirement to Disclose Personal Information
You are not required to provide us with any personal data. However, in certain circumstances, withholding personal data may prevent us from delivering the Services or granting you access to the website.
4. What Personal Data We Collect
4.1 This includes information about 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 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 connecting with a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party platforms to facilitate trading: this 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 set out 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 for one or more specified purposes, including its transfer to a third-party trading platform.
- Processing of personal data may also be required to serve the legitimate interests of the Company or a third party — for example, to improve Our Services or to defend 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 Below is a list of the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
At your request, we may collect and 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 necessary to address any questions you may have about the Services.
Processing of personal data may also be necessary to serve the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, or 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. This includes crash reports and malfunction data collected in connection with the Services.
Processing must be necessary to serve the legitimate interests of the Company or 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 functions, business development, strategic decision-making, and oversight mechanisms.
Processing personal data may be necessary 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.
Processing data is necessary 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 necessary to protect 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, as well as companies that analyse user experience and IP address information.
6.2 You may also request that we transfer specific personal data about you to third-party trading platforms. In such cases, we will share the personal data you have provided to us directly with those platforms. 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 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 its customers.
Where necessary to protect the rights of third parties or their assets, the Company may disclose personal data to regulatory, local, or other competent 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 such as the transfer or sale of Company assets, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business 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 are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytical 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 required to provide the features and functionality you've requested and to ensure smooth navigation across our website. They enable your device to download and stream data, access the information, products, and services you've asked for, and return to previously visited pages.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify that you are logged in. They are deleted when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies let us 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 statistical data on site performance and to carry out analysis that helps us improve your experience.
Additional Information
Cookies store anonymous data that cannot be linked to any identified or identifiable individual. Some cookies are deleted when you close your browser; others remain valid indefinitely.
7.4 If cookies are blocked or removed, you'll need to adjust your browser settings. The links below guide you through the process for some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please be aware that disabling cookies may cause some or all Website features to behave unexpectedly or stop functioning altogether.
Online Tracking Notice: This service does not currently recognise do-not-track signals.
8. Retention of Personal Data
The Company will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for 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 continued sharing, we will do so for a further 12 months.
8.3 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 organisations. The Company takes all necessary steps to protect your personal data and ensure that you retain the ability to exercise your rights and access effective legal remedies.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area):
- Transfers to a third country or international organisation that the European 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 European 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, contact us at: support@lodestarkapiton.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 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, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
10.3 Where required by legal or other obligations outside our control, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we cannot control how those third parties 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.
When visiting any third-party websites or apps, read their privacy policies before accessing or using them. Exercise caution about any personal data you share with 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 explicitly stated otherwise, any amendments to this Policy take effect upon publication of the revised version.
13. Your Rights
You may request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal data.
If you are an EEA resident, please refer to this page for details on the rights available to you in relation to your Personal Data. To exercise any of these rights, contact us at the email address below.
13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of your Personal Data upon request and may charge a reasonable fee for additional copies. This right must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.
13.4 Right to rectification You have the right to request correction of any inaccurate Personal Data held about you. You may also request that incomplete Personal Data be rectified, taking into account 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 processing of your Personal Data that is based on legitimate interests pursued by Us or by 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 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, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another natural person, 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, 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 does not adversely affect the rights or freedoms of others.
13.8 Right to Object You have the right at any time to object 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 do so. 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 to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent prior to that withdrawal. You have the right to 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 within the European Union. 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 provided in response to a request under your section 13 rights will be made available free of charge. Where a request is unjustified or excessive, in particular where requests are repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the action requested, or we may decline to act.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide adequate proof of identification.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Lodestar Kapiton 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@lodestarkapiton.com