Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, including how it 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 In 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 and are not designed for use by anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we permit them to use our services. If we become aware that such information has been collected, 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.

2.2 We also 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is not personal in nature 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 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 used to protect legitimate interests, please contact us by email.

5.4 The following outlines the purposes and legal bases 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, as well as platforms that analyze user experience and IP address data.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us to 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 third-party 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.

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 competent authorities.

We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of assets, or 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 service providers — such as advertisers and analytics companies — 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 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 see. Cookies are also used for statistical and analytics purposes.

7.3 We use two types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognize you as a returning user, allowing the website to restore your previous session.

7.5 Please be aware that disabling certain functions may cause some or all Website features to behave unexpectedly.

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 any longer period 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 required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organizations. The Company takes all necessary steps to protect the personal data you provide and to ensure that your rights remain enforceable and that effective legal recourse is available to you.

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

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 without error, nor can we be held liable 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, unauthorized access by a third party, or any other cause beyond our reasonable control.

10.3 Where required by legal or other obligations beyond our control, we may be required 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 fully secured. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how those sites or applications 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, review their privacy policies before accessing or using their services. Exercise caution when sharing Personal Data with them.

12. Modifications to This Policy

12.1 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 publish 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 verification of the accuracy of your Personal Data we collect, to correct any inaccuracies, and to have Personal Data deleted where it is no longer required by us. You may also restrict the types or scope 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, please contact us at the email address below.

13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. If Personal Data is being processed, you have the right to access it. The Company will provide an electronic copy of your Personal Data and may charge a reasonable fee for additional copies. If requested, data will be provided in electronic form. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request is detrimental to the rights or freedoms of another individual, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data relating to you be corrected, taking into account the purpose of processing.

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 to the processing of your Personal Data based on a reason specific to your situation, where processing relies on legitimate interests pursued by Us or a third party; (e) the Personal Data are 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 fulfill an obligation required 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 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 your consent or on 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 must not adversely affect the rights or freedoms of others.

13.8 Right to Object You have the right to object at any time 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. If we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where the processing relates to the establishment, exercise, or defense of legal claims, we may continue to process your Personal Data despite your objection. 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 prior to that point. You have the right to lodge a complaint with your relevant supervisory authority. Within the European Union, you may also submit a complaint to a supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that applicable EU and member state laws may limit the rights described in this section 13.

We will provide the information you are entitled to under Section 13 of this agreement within one month of receiving your request. If 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, along with the reasons for it, within one month of receiving your request.

Provided your request falls within the rights outlined in section 13 of the applicable law, the information you request will be provided at no cost. However, if a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, 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 individual to provide suitable means of verification.