Kolwick Fundvale

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

Last updated: 01.06.2026

We (also referred to as "We", "Us", or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy explains how we collect and store the information you provide through the website Kolwick Fundvale (the "Website").

We want you to be able to make informed decisions about how your Personal Data is used and processed. We use various methods and procedures to provide you with relevant information. When we believe specific details are needed, we'll share them with you at the appropriate time. We're happy to answer any questions you may have, subject to any legal limitations.

By using our Website, you confirm that you have read and accepted this Privacy Policy. For questions: support@kolwick-fundvale.com

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 this information.

1.2 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 additional information that we hold or can access.

1.3 The Policy defines "processing" as any operation that involves the use or collection of Personal Data. This includes organizing, structuring, and storing Personal Data.

1.4 Our services are designed for general audiences and are not intended for use by anyone under 18 years of age. We do not knowingly collect or solicit information from individuals under 18. We do not knowingly permit such individuals to use our services. If we become aware of any information collected from minors, we will delete it as promptly 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 cases, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analyzing 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, failure to supply Us with Personal Data may prevent Us from offering the Services or may restrict your access to the website.

4. What Personal Data We Collect

4.1 This includes information about your online activity log and data about your traffic, including:

  • 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 you collect is not personally identifiable and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you provide to us at your discretion when you connect to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to enable 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 The company processes your Personal Data for the purposes outlined in this section and in accordance with the applicable legal basis.

5.2 Without a legal basis, the Company cannot use your Personal Data. The legal grounds that enable the Company to process your Personal Data are:

  • You have provided your consent for the processing of your Personal Data for one or more specific purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
  • The Company or a third party may need to process data to meet their legitimate interests. For example, this may be necessary to enhance Our Services or to defend against legal claims.
  • Processing must meet an obligation of law.

5.3 Contact us via email for more details regarding the processing necessary to safeguard 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:

Scope

Legal Basis

1. To share your personal information with third parties at your request for digital trading access
When you request it, we may collect your Personal Data 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 is necessary to help us answer any questions you may have regarding the Services.

Processing is necessary to serve the legitimate interests of the Company or a third party.

3. To comply with legal, administrative, judicial, or regulatory obligations, Personal Data is processed as required by law.

To ensure compliance with legal obligations, processing is required.

4. To enhance Our Services Personal
Data may be used by us to enhance Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.

Processing is necessary to serve the legitimate interests of the Company or a third party.

5. To stop fraud and misuse of Our Services.

Processing is necessary for the legitimate interests of the Company or those of a third party.

6. To carry out and oversee activities that comply with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, oversight processes, and similar functions.

Processing is necessary for the legitimate interests of the Company or a third party.

7. To conduct analysis, such as statistical analysis
To make decisions on various issues, we use different analytical techniques (including statistical methods).

Processing is necessary to serve the legitimate interests of the Company or a third party.

8. To safeguard our assets, rights and interests as well as those of third parties
Personal Data may be processed by us in order to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.

Processing is necessary to serve 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, such as hosting and storage companies, for purposes including IP address management 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 your Personal Data to those third-party platforms. The use of your Personal Data will be governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with affiliated 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 In the event that it becomes 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 group company if such a transaction occurs (including the transfer or sale of assets belonging to the Company or any group company), 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 advertising providers and analytics companies, may be used on our website. These companies may also use cookies or similar technologies.

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 behavior to enhance user experience, remember your settings, and tailor products and services to your interests. 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 remain active only until you close your browser. Other cookies are persistent, meaning they stay on your device for a period of time even after you close your browser. These help the Website recognize you as a returning user and make it easier for you to come back to the site.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are essential for accessing the features you've requested and navigating our website. They enable us to provide the information, products, and services you've asked for.
They allow your device to download and stream data, letting you move around the site, use its features, and return to pages you've previously visited.

Additional Information

Cookies gather Personal Data, including your username and most recent login date, to verify that you're logged in to the site. They are deleted when you close your web browser (session Cookies).

The type of cookie

Functionality Cookies

Scope

Cookies enable us to recognize you on each visit to our site and remember your settings and preferences.

Additional Information

They remain active until their expiration date and are stored even after the browser is closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow Us to conduct analysis on our website.

Additional Information

Cookies store anonymous data that is not associated with any identifiable natural person. They can be removed when you close your browser. Other cookies remain valid indefinitely.

7.4 Cookies are blocked or removed. To prevent or remove cookies, you need to adjust your browser's settings. Below are links to help you with the process for some of the most popular browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please note 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 required or permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for an additional 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 third countries or international organizations). The Company takes all necessary steps to safeguard the personal data you provide and ensure that you retain the ability to assert your rights and access effective legal remedies.

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 adequate protection 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")
  • The transfer is conducted under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
  • The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

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@kolwick-fundvale.com

10. Security of Personal Data

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

10.2 We cannot guarantee that your Personal Data will remain secure without error. We are also not liable for any intangible, incidental, or consequential damages resulting 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 any other cause beyond our control.

10.3 If we are required by law or other circumstances beyond our control, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we cannot guarantee the security measures these third parties apply to your Personal Data.

10.4 Personal Data cannot be transferred over the web in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party sites and applications are provided on the website. 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 applications. This Policy does not apply to actions taken through such sites or applications.

11.2 When you visit any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use their services. We also suggest exercising caution when providing any Personal Data to them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If we modify this Policy, we will notify you of the changes by posting the revised version on our website.

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

12.3 Unless explicitly stated otherwise, any amendments will take effect upon publication of the updated Policy.

13. Your Rights

13.1 You have the right to request verification of the accuracy of your Personal Data we collect, to correct any errors, and to delete any Personal Data we no longer need. You may also limit the types of processing of your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights are accessible to you regarding the Personal Data you provide. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If applicable, 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 capacity to fulfill it.

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 corrected, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed 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 at any time, based on a reason 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 unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the company. This right does not apply if the processing is necessary (a) to fulfill an obligation under European Union law 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 for the purpose of establishing, exercising, or defending legal claims, or protecting 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 If processing is carried out by an automated system 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. You are entitled to 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 interfere with the rights or freedoms of others.

13.8 Right to challenge You have the right to object at any time to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on these 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 defense of legal claims—we may continue processing. Otherwise, we will cease processing upon your objection. 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 revoke your consent for Us to process your Personal Data at any time. This will not affect the legality or lawfulness of any processing that relied on your consent before its withdrawal. You are entitled 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 in relation to your Personal Data, as detailed 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 complexity and volume of requests. If an extension is required, we will inform you within one month of receiving your request and explain the reasons for the delay.

13.11 As long as it does not contradict the provisions of Section 13 of the law, the information you request under your rights pursuant to Section 13 will be provided free of charge. If your request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also choose not to act.

13.12 If we have doubts about the identity of the actual person who submitted your request, we may ask you to provide reasonable means of identification.

This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.

Kolwick Fundvale 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@kolwick-fundvale.com