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 (referred to as "We", "Us", or "Our") 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 Slate Capivex (the "Website").
We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods to provide you with relevant information. Where we believe specific details are needed, we will provide them at the appropriate time. We are happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy describes the types of Personal Data the Company collects about natural individuals, and how it processes, shares with third parties, and secures that data.
1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or by combining additional information that we hold or can access.
1.3 Under this Policy, "processing" means any operation that uses or collects Personal Data, including its management, structuring, and storage.
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 anyone under 18, nor do we knowingly permit such individuals to use our services. If we learn that we hold information about a child, we will delete it as quickly as possible.
2. What Personal Data Do We Have on You
2.1 We collect Personal Data when you access our services and channels or visit our website. In certain cases, we may request your Personal Data directly.
2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information about you 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, withholding it 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, along with 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
4.2 The information we 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 with a third party's online trading platform through Us.
4.4 Personal information you provide directly 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 of Personal Data
5.1 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.
5.2 The Company cannot use Personal Data concerning you without a legal basis. The legal grounds on which the Company may process Personal Data concerning you are:
- 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 transfer it to a third-party trading platform.
- We or a third party may process personal data to serve a legitimate interest, such as improving Our Services or defending legal claims.
- Processing must meet an obligation of law.
5.3 Contact us by email for more details on the processing necessary to safeguard our legitimate interests.
5.4 Below are the reasons and legal grounds on which we may use the information you provide:
Scope
Legal Basis
To provide your personal information to third parties at your request to access digital trading
If you request it, we may collect Personal Data from you to forward 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
Personal Data helps us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed to meet legal obligations and to comply with administrative, judicial, or other legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
These include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We apply a range of analytical methods, including statistical ones, to inform our decisions on various matters.
Processing is necessary for the legitimate interests of the Company or a third party.
8. To protect our assets, rights, and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in compliance with any applicable laws, regulations, or agreements, and any terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company 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, such as hosting and storage providers, including IP address information and analysis of user experiences.
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 give to us to these third-party trading platforms. Any use of your Personal Data is 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 provides the resources needed to enhance the products and services offered to its customers.
6.4 To safeguard the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in the group, in the event such a transaction takes place (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 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or similar technology.
7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain only until you close your browser. Others are persistent cookies, which stay on your device for a period after you close your browser. These help the Website recognize you as a returning user and make it easier to come back to the site.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you request and to navigate our website. They enable us to deliver the information, products, and services you have asked for.
They allow your device to download and stream data, so you can move around the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm that you are signed in. These are deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies let us recognize you on each visit and remember your preferences.
Additional Information
They remain valid until their expiry date and persist even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies help us collect statistical data on the site's performance, support ongoing improvements, and carry out analysis of our website.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable natural person. Some are deleted when you close your browser, while others remain valid indefinitely.
7.4 Blocking or removing cookies. To block or remove cookies, adjust your browser's settings. The links below explain the process for several of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Be aware that some or all of the Website's functions and features may not work as you expect if this occurs.
Online Tracking Notice: This service does not currently respond to 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 purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
8.2 We will share your personal data with third-party trading platforms for a period of 12 months. With your consent, this sharing will continue for an additional 12 months.
8.3 We regularly review the Personal Data we hold to confirm it is still needed.
9. International Transfers
9.1 Your personal information may be transferred to other countries, including to third countries or international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities, in line with Article 46(2)(a)
- The 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 about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Email: support@slatecapivex.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any intangible, 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 access by a third party, or any other cause beyond our control.
10.3 Where required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your Personal Data.
10.4 No method of transmitting Personal Data over the internet is completely secure. The Company cannot guarantee the security of Personal Data you transmit to Us online.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications that are not under the Company's control. We are not responsible for how these sites or applications collect or process Personal Data. This Policy does not apply to any actions taken through them.
11.2 When you access any third-party website or app, we recommend reviewing their privacy policy before deciding to use it. We also advise caution before providing any Personal Data to them.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If we make changes, we will notify you by posting the updated Policy on our website.
12.2 We will also notify you of any significant changes to this Policy through methods we consider appropriate and will post an announcement on our website.
12.3 Unless otherwise stated, any amendments take effect once the revised Policy is published.
13. Your Rights
13.1 You may request that We verify the accuracy of the Personal Data We hold about you, correct any errors, and delete any Personal Data We no longer require. You may also restrict the types of processing applied to your Personal Data.
13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, submit a request by email to the address below.
13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, 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 additional copies. If you request it, the data will be provided electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request adversely affects the rights and freedoms of another person, the Company may refuse to comply with it or limit the extent to which it does so.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.
13.5 Right to Erasure This right applies where: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfill a legal obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Restriction of 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 such a restriction, the 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 for reasons of significant 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 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. You may also 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 object You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based on those legitimate interests. Where we can establish compelling legitimate grounds for processing, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests override those grounds, or that the processing relates to the establishment, exercise, or defense of legal claims. Regarding direct marketing, you have the right to object at any time to processing of Personal Data concerning you.
13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You also have the right to lodge a complaint with your supervisory authority. You may file an appeal with a supervisory authority established by a member state to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights regarding Personal Data concerning you, as set out in this section 13.
13.10 We will provide the information you request under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
13.11 Provided it does not conflict with section 13 of the law, the information you request under your section 13 rights will be provided free of charge. Where a request is unfounded or excessive, in particular because it is repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or taking the requested action. 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 proof of identity.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Slate Capivex 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@slatecapivex.com