Privacy Policy

1. The Scope

1.1 This policy explains what Personal Data the Company collects about natural individuals, and how it processes, shares with third parties, and secures that data.

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 information we hold or can reasonably access.

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

Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we knowingly permit them to use our services. Should 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 circumstances, we may ask you to provide personal data directly.

2.2 In other 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is not personal data 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 trading 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 set out in this section, in accordance with the applicable legal basis.

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

5.4 The following sets out 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 data handlers, and user experience analytics services.

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 is governed by the respective privacy policies of those third-party platforms. Please note that your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with related entities or business partners to support the enhancement and improvement of the products and services provided to 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 prospective investors, buyers, or lenders to the Company or any other group company in connection with a transaction (including the transfer or sale of Company or group company assets), or as part of any merger, restructuring, consolidation, or insolvency proceedings involving the Company or any other group company.

7. Cookies and Services from Third Parties

7.1 We may work with third-party services, such as advertisers and analytics providers, who operate on our website. These third parties may also use cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit the website. They are used to gather information about your preferences and browsing habits, 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 recognise you as a returning user and help you pick up where you left off.

7.5 Please note that disabling cookies may cause some or all Website features to behave unexpectedly or stop working altogether.

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

8. Retention of Personal Data

We will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for such longer periods as permitted by applicable law, regulation, or order.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to this, 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 organisations. The Company takes all necessary steps to protect the personal data you provide and to ensure that you retain the right to assert your rights and access effective legal recourse.

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

10. Security of Personal Data

We have implemented appropriate organisational and technical measures to protect personal data against accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your Personal Data will be held securely and free from error at all times. We are 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.

10.3 Where we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as 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 guarantee 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 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 accessing or using them. Exercise caution about any personal data you share 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 Personal Data collected about you, 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 Data.

If you are a resident of the EEA, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, please contact us at the email address below.

13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, where it is, to access that data. 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 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 rectify inaccurate Personal Data. You may request that incomplete Personal Data relating to you be corrected, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request 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 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) 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 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 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 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 to object at any time to the processing of Personal Data concerning you where that processing is based on the legitimate interests of the Company or a third party. This right is not limited to profiling based 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. 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 for Us processing Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by a Member State to protect 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 set out in this section 13.

We will respond to your request within one month of receipt, in accordance with the rights set out in section 13 of this agreement. Where necessary, this period may be extended by up to two months, depending on the complexity and volume of requests received. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information provided in response to a rights request will be supplied free of charge. Where a request is manifestly unfounded or excessive — in particular where it is repetitive — we may either charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or refuse to act on the request.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that individual to provide suitable proof of identity.