Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about individuals, and how that data is processed, shared with third parties, and secured.

1.2 This Policy applies to information relating to an identified or identifiable natural person. A natural person is considered identifiable if they can be identified directly, or through a combination of additional information we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organization, structuring, and storage.

Our services are intended for general audiences. We do not permit anyone under the age of 18 to use our services, and we do not knowingly collect information from minors. If we become aware that we have collected personal information from 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.

In some 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, withholding it may prevent us from delivering the Services or restrict your access to the website.

4. What Personal Data We Collect

The information collected is not personal information and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when connecting to 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.

For details on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following outlines the purposes 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 share personal data with third-party service providers, including hosting and storage providers, IP address processors, and user experience analytics platforms.

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 relevant Personal Data you have supplied to us directly to those platforms. Your Personal Data may be shared with more than one trading platform, and its use will be governed by each platform's own privacy policy.

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.

6.4 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 such as a transfer or sale of company assets, a merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity 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 — that operate on our website. These third parties may use cookies or similar tracking technologies independently.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor 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 allow the Website to recognize you as a returning user and help you resume your session.

7.5 Please note that disabling cookies may cause certain features or functions on the Website to not work as intended.

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

8. Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for such 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, we will continue sharing your data for a further 12 months.

We periodically review the Personal Data we hold to confirm it is no longer needed.

9. International Transfers

Your personal information may be transferred to other countries or to international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure you can effectively assert your rights and access legal recourse.

9.3 We can provide information about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@vestmarel.net

10. Security of Personal Data

We have implemented appropriate organizational and technical measures to protect Personal Data against accidental or unlawful destruction, loss, or modification.

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, unauthorized third-party access, or other causes beyond our reasonable control.

10.3 In some 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 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 operated or supervised by the Company. We are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such third-party sites or applications.

11.2 When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. We also advise exercising caution when sharing any Personal Data with them.

12. Modifications to This Policy

This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy 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 Personal Data we collect about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope or types of processing applied to your personal information.

If you are a resident of the EEA, please refer to this page for details on 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 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 currently being processed and may charge a reasonable fee for additional copies. This right to access must not infringe upon 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 The Company may correct any inaccurate Personal Data it holds about you. You have the right to request that incomplete Personal Data be rectified, 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 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 based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required 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 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 in a structured, commonly used format and to request that it 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 may not be exercised where doing so would adversely affect the rights or freedoms of others.

13.8 Right to Challenge 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 right is not limited to profiling based solely on those legitimate 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 process your Personal Data despite your objection. Concerning 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 prior to that withdrawal. You have the right to lodge a complaint with a relevant supervisory authority. Within the European Union, you may lodge a complaint with a 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 the rights described in this section 13.

We will respond to requests made under the rights described in 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 additional months. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights 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 carrying out 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 person to provide a reasonable means of verifying their identity.