Privacy Policy

1. The Scope

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

This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified 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 organisation, structuring, and storage.

Our services are intended for general audiences. We do not permit anyone under the age of 18 to use our platform, and we do not knowingly collect information from minors. If we become aware that we hold data belonging to 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 also request personal data directly 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 our Services or granting you access to the website.

4. What Personal Data We Collect

The information collected is non-personal 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 more information on the processing carried out to protect legitimate interests, contact us by email.

5.4 The following outlines 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 share Personal Data with third-party service providers, including hosting and storage providers, as well as companies that analyse 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. Where you make such a request, we will provide the relevant Personal Data to those platforms accordingly. Your Personal Data shared in this way will be governed by each platform's own privacy policy. 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 affiliated entities or business partners to support the development and improvement of the products and services provided to customers.

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, buyers, or lenders to the Company or any other company within the group if a relevant transaction takes place — including the transfer or sale of company assets, or in connection with 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 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 analytics and statistical 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 recognise you as a returning user and help you resume access without starting from scratch.

Please note that some or all Website 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

The Company will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for 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 to continued sharing, we will extend this for a further 12 months.

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

9. International Transfers

9.1 Your personal data may be transferred to other countries or shared with international organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@sterlingfondvale.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 alteration.

We cannot guarantee that your Personal Data will be kept secure without error at all times. 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, unauthorised third-party access, or other causes beyond our reasonable control.

In certain 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 handle or 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 Our website may contain links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

When visiting any third-party websites or apps, read their privacy policies before deciding to access or use them. Exercise caution about any Personal Data you share with them.

12. Modifications to This Policy

This Policy may be updated at any time. When changes are made, the updated Policy will be posted 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 verification of the accuracy of your Personal Data being collected, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the scope of processing of 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 request to the email address below.

13.3 Access rights You have the right to verify 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 conflict with the rights and freedoms of others. Where complying with 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 inaccurate Personal Data. You have the right to request that incomplete Personal Data relating to you be rectified, 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, on grounds relating to your specific situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or by a third party; (e) the Personal Data have been 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 an obligation imposed by law, including 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 ask the Company to restrict its processing. Where a restriction is in place, 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 the Personal Data you have provided to the Company in a structured, commonly used format. You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right 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 at any time to object 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. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing relates to the establishment, exercise, or defence of legal claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for such purposes.

13.9 Right to Withdraw Consent You may withdraw your consent for Us to process your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You have the right to lodge a complaint with your relevant supervisory authority. Within the European Union, you may lodge a complaint with the supervisory authority established by a Member State to protect individuals' fundamental rights in relation to the processing of Personal Data. Note that EU and Member State laws may limit the rights described in this section 13.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity or volume of requests. If an extension is required, we will notify you within one month of receiving your request and provide the reasons for the delay.

Subject to the provisions of section 13, information requested under your rights in that section 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 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 person to provide adequate proof of identity.