Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects about natural individuals, including how it processes that data, shares it with third parties, secures its processes, and related matters.

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 we have or can access.

1.3 The Policy defines "processing" as a process requiring the use or gathering of Personal Data, including the management, structuring, and storage of 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 anyone under 18 years old, nor do we knowingly allow such persons to use our services. If we learn that we hold information about children, we will erase it as soon as possible.

2. What Personal Data Do We Have on You

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

2.2 In other instances, we gather your Personal Data by analysing your use of 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, not supplying Us with Personal Data could prevent Us from providing the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.2 The information you collect is not private information 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 online trading platform through Us.

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

5.3 Contact Us by email for more details about the processing necessary to safeguard the legitimate interests.

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

6. Transfer of Personal Data to Third Party

6.1 The Company may also provide Personal Data to third-party companies that provide services to us, such as hosting, storage, IP address information, and analysis of user experiences.

6.2 You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you give to Us to those third-party trading platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data could be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This may provide the Company with the resources needed to enhance and improve the products and services it provides to its customers.

6.4 Where necessary 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 Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in the group of companies, if 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 Third-party services, such as advertising providers 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 placed on your device whenever you visit or access the website. They collect information about your preferences and browsing habits to improve user experience, remember your preferences, and customise products and services that may interest you. Cookies are also used for statistics and analytics.

7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They help the Website identify you as a returning user and allow users to return to the Website.

7.5 However, be aware that some or all Website functions and features might not operate as expected if this happens.

Online Tracking Notice: This service does not currently support do-not-track signals.

8. Retention of Personal Data

8.1 The Company will retain Personal Data about you for as long as necessary to fulfil the purpose of processing Personal Data, as described in this Policy, or for longer time periods as permitted by law or regulations, policies, and applicable orders.

8.2 We will share your information with trading platforms operated by third parties for 12 months. If you agree to this, we will continue sharing your data for another 12 months.

8.3 We regularly review the Personal Data we retain to ensure it is no longer needed.

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 organizations). Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users can assert their rights and access effective legal recourses.

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

10. Security of Personal Data

10.1 We have taken appropriate organisational and technical precautions to safeguard Personal Data, including measures to prevent its accidental or illegal destruction, loss, or modification.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.

10.3 Where legal obligations or other obligations beyond our control apply, we may be required to provide Personal Data concerning you to third parties, such as public authorities. In these situations, we cannot control the security provided by third parties for your Personal Data.

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

11. Hyperlinks to Third Party Websites

11.1 The website provides links to third-party sites and applications. These applications and websites are not under the supervision of the Company. We are not responsible for the gathering 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 that you read their privacy policies before deciding whether to access or use their apps or provide any Personal Data to them.

12. Modifications to This Policy

12.1 This Policy is subject to change at any time. If we change this Policy, we will notify you of the changes by posting the updated Policy on our website.

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

12.3 Unless explicitly specified, any amendments will become effective after the revised Policy is published.

13. Your Rights

13.1 You are entitled to request that we verify the accuracy of Personal Data being collected about you, rectify any mistakes, and delete all Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights are available to you with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by emailing the address below.

13.3 Access rights You have the right to obtain confirmation from the Company as to whether Personal Data concerning you is being processed. If it is, you may access your 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. 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 adversely affects the rights and freedoms of another person, the Company may refuse to comply with the request or limit its capacity to fulfil it.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You are entitled to demand rectification of any insufficient Personal Data concerning you, taking into account the reason for processing.

13.5 Right to Erasure The following reasons apply: (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 either by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to comply with the company's legal obligation. This right does not apply where processing is necessary: (a) to fulfil an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to create, exercise or defend legal rights.

13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, Personal Data may only be kept with your consent, to create, exercise or defend legal rights, to defend the rights of another natural individual, or for reasons of significant public interest within the European Union or a Member state.

13.7 Right to data portability If the processing is carried out by automated means and is based on consent or a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. 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 right to erasure. The right to transfer data does not affect the rights or freedoms of others.

13.8 Right to challenge You have the right to object at any time to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can establish compelling legitimate grounds for processing Personal Data, we will not be able to continue that processing unless you can prove that those grounds outweigh your rights, freedoms, or interests, or the exercise, establishment, or defence of legal rights. For direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.

13.9 Right to refuse consent You may revoke your consent to Us processing Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may lodge an appeal with a supervisory authority set up by a member state to safeguard the fundamental rights of individuals in relation to 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 Personal Data concerning you, as detailed 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 time frame may be extended to up to two months if needed, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.

13.11 Provided it does not conflict with the provisions of section 13 of the law, the information you request pursuant to your rights under section 13 will be made available free of charge. If the request is not justified or is excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative expenses of providing the information or communicating the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the real person who submitted your request, we may ask the person making the request to provide reasonable means of identifying themselves.