Privacy Policy

We are committed to being transparent about how we collect and process your personal information.

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods to keep you properly informed at every relevant stage. Where specific information is needed, we'll provide it at the appropriate time. We're happy to answer any questions you have and can clarify any limitations imposed by law. You can reach us by email at: info@boldswaptorine.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for the following purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site and protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities related to the Services. We also process your personal data to better understand your preferences and needs.

To exercise your rights regarding your Personal Data, you have access to the following tools:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request.

Protect Your Personal Data:

While complete security of your Personal Data cannot be guaranteed, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This Policy describes the types of personal data the Company collects about natural individuals, and how that data is processed, shared with third parties, and secured. This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through a combination of additional information the Company holds or can reasonably access. For the purposes of this Policy, "processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage. Our services are intended for general audiences aged 18 and above. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. This may happen directly when you provide it to us, or indirectly through analysis of how you use our services and channels, or through information received from our third-party partners.

You are not required to disclose personal information to the company. However, withholding such information may prevent us from delivering our Services or granting you access to the website.

Providing personal data is not mandatory. However, withholding it may prevent us from delivering the Services or limit your access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes data about your online activity and traffic — such as your IP address, access dates and times, language settings, browser type, software crash logs, and device information. This data is non-personal and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily provide when connecting to a third-party online trading platform through Us.
Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data We process your personal data only where we have a valid legal basis to do so. The specific legal basis depends on the type of data involved and the purpose for which it is processed. In each case, we process your personal data for one or more of the following reasons: — To perform a contract with you, or to take steps at your request before entering into a contract. — To comply with a legal obligation to which we are subject. — To protect your vital interests or those of another person. — Where processing is necessary for the legitimate interests pursued by us or a third party, provided those interests are not overridden by your rights and interests. — Where you have given your consent to the processing of your personal data for one or more specific purposes. Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal. Where providing personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, failure to provide the requested data may prevent us from delivering our Services or granting you access to the website.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances. Service Providers: We work with trusted third-party service providers who assist in operating our platform and delivering our services. These providers access personal data only to the extent necessary to perform their designated functions and are contractually bound to protect it. Business Transfers: If we undergo a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a different privacy policy. Legal Obligations: We may disclose personal data when required by law, court order, or lawful request from a government or regulatory authority. Protection of Rights: We may share personal data where necessary to enforce our Terms and Conditions, protect the rights or safety of our users, or prevent fraud or misuse of our platform. Consent: Where required, we will share your personal data with third parties only with your explicit consent. In all cases, we take reasonable steps to ensure that third parties handle your personal data securely and in accordance with applicable data protection requirements. We do not sell your personal data to third parties.

We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers, as well as companies that help us analyze user experience. Upon your request, we may also share specific Personal Data with third-party trading platforms you designate. In such cases, your Personal Data will be transferred to those platforms and governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform. We may share Personal Data with related entities or business partners where doing so enables us to develop and improve the products and services we offer our customers. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities. We may also share your Personal Data with prospective investors, acquirers, or lenders — whether in relation to the Company or any entity within the same group — in connection with a proposed or completed transaction, including the transfer or sale of assets, or any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any group entity.

7. Cookies and Third-Party Services Our website uses cookies and services provided by third parties. These third parties may collect and process data about your activity on our site in accordance with their own privacy policies. By using our website, you consent to the use of such cookies and third-party services. You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Please note that disabling certain cookies may affect the functionality of our website or limit access to some features.

We may work with third-party service providers, including advertising partners and analytics companies, who may also use cookies or similar tracking technologies on our website.
Cookies are small text files placed on your device when you visit our website. They are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and tailor the products and services presented to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognise you as a returning user and make it easier for you to navigate the site on future visits.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We 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.
We share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We regularly review the personal data we hold to confirm it is no longer needed.

9. Transfers of Personal Information to a Third-Party Country or International Organisation We may transfer your personal data to recipients located in third-party countries or within international organisations. Where such transfers occur, we ensure appropriate safeguards are in place in accordance with applicable data protection requirements. By using our services, you acknowledge that your personal data may be transferred, stored, or processed outside your country of residence, including in jurisdictions where data protection laws may differ from those in your home country. Any such transfer will be carried out only where permitted under applicable law and subject to measures designed to protect the security and integrity of your personal data. These may include standard contractual clauses, binding corporate rules, or other legally recognised mechanisms. If you require further information about the safeguards applied to cross-border transfers of your personal data, you may contact us through the details provided in this policy.

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organisational measures to safeguard it against unauthorised access, loss, misuse, alteration, or disclosure. While we apply industry-appropriate security practices, no method of data transmission or storage is entirely risk-free. We cannot guarantee absolute security, but we continually review and update our measures to maintain appropriate protection. You also play a role in keeping your data secure. You are responsible for maintaining the confidentiality of any account credentials and for ensuring that access to your devices is appropriately controlled. If you believe your account has been compromised, notify us immediately. Personal data may be retained for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. When retention is no longer necessary, we will securely delete or anonymise your personal data in accordance with our internal data management procedures. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will take appropriate steps to address the breach and notify relevant parties as required.

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained free of error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including, but not limited to, disclosures resulting from transmission errors, unauthorized third-party access, or other causes beyond our control. Where required by legal or regulatory obligations beyond our control, we may be required to disclose your Personal Data to third parties, including public authorities. We cannot control the level of security applied to your Personal Data by such third parties in those circumstances. Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us through the internet.

11. Links to Third-Party Websites

Our website may contain links to third-party websites and applications. These sites and apps 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 apps.
Before accessing or using any third-party website or app, we recommend reviewing their privacy policy carefully. We also advise exercising caution before providing any Personal Data to them.

12. Modifications to this Policy We may update this Policy from time to time. When changes are made, the revised Policy will be published on our website with an updated effective date. Continued use of our services after any changes take effect constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed of how your information is handled.

Before accessing or using any third-party websites or apps, read their privacy policies carefully. Be mindful of any personal data you share with them.

13. Your Rights Regarding Your Personal Information You have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us using the details provided in this policy. Right of access — You may request a copy of the personal data we hold about you, along with information about how we use it. Right to rectification — If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. Right to erasure — You may request that we delete your personal data where there is no compelling reason for us to continue processing it. Right to restrict processing — You may request that we limit how we use your personal data in certain circumstances. Right to data portability — Where processing is based on your consent or a contract, you may request that we transfer your personal data to you or to a third party in a structured, commonly used, machine-readable format. Right to object — You may object to our processing of your personal data where we rely on legitimate interests as our legal basis, including processing for direct marketing purposes. Right to withdraw consent — Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before the withdrawal. Where you exercise any of these rights, we will respond within a reasonable timeframe and in accordance with applicable law. In some cases, we may need to verify your identity before acting on a request.

You have the right to request that we verify the accuracy of Personal Data being collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. 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:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please send a written request to the email address below.
Access rights
The Company can verify whether your Personal Data is being processed. If it is, you may request access to 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. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.
Right to rectification
The Company will correct inaccurate Personal Data upon request. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is processed.
Right to erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
Where processing is restricted, Personal Data may only be stored with your consent, or to establish, exercise, or defend legal claims, to protect the rights of another person, or where there is a significant public interest within the European Union or a Member State.
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 request that your Personal Data be transferred directly from the Company to another controller where technically feasible. Exercising this right does not affect your right to erasure, nor does it infringe on the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. If we cannot demonstrate compelling legitimate grounds that override your rights, interests, or freedoms, or that are necessary for the establishment, exercise, or defense of legal claims, we will cease processing.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
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 prior to that withdrawal.
You have the right to lodge a complaint with a supervisory authority. You may 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 within the European Union.
European Union and Member State law may limit the rights described in this section 13 as they relate to your Personal Data.
We will respond to requests submitted under the rights in section 13 within one month of receipt. Where necessary, and depending on the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Unless otherwise stated under section 13, information provided in response to your rights requests will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person making a request, we may ask for additional information to confirm their identity.