Privacy Policy

1. The Scope

1.1 This policy explains what personal data the Company collects about natural individuals, and how that data is processed, shared with third parties, and secured.

This Policy covers 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 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 aged 18 and over. We do not knowingly collect information from anyone under 18, nor do we permit anyone under 18 to use our services. If we become aware that we hold information relating to a minor, 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 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 information 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 more information about how we process data to protect legitimate interests, 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, IP address data handlers, and user experience analytics services.

6.2 You may also request that we share your Personal Data with third-party trading platforms. In such cases, we will provide the Personal Data you have supplied to us directly to those platforms. Your Personal Data may be shared with multiple third-party trading platforms, and its use will be governed by their respective privacy policies.

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 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 assets, 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 services — such as advertisers and analytics providers — 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 most relevant to you. Cookies are also used for statistical and analytics purposes.

7.3 Some cookies used on this website 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 make it easier to resume your session.

Please note that some or all Website features and functions may not work as expected if this occurs.

Online Tracking Notice: This service does not currently respond to 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 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 to continued sharing, we will share 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 international organisations. The Company takes all necessary steps to protect your personal data and ensure you retain the ability to exercise your rights and access effective legal recourse.

9.3 We can provide details on 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@suretiform.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 kept secure without error. 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 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 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 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.

When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Only provide personal data to them once you are satisfied with how it will be handled.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be reflected in the updated Policy 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 Personal Data collected about you, to correct any inaccuracies, and to request deletion of any Personal Data we no longer require. You may also restrict the types of processing applied to 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 by email at the 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 the 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 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 We may correct any inaccurate Personal Data we hold about you. You also 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 erasure of your Personal Data in the following circumstances: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis to process; (c) you object, based on reasons specific to your 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) the Personal Data must be erased to fulfil a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by 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 of that data. Where 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 reason 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 does not adversely affect the rights or freedoms of others.

13.8 Right to challenge You have the right to object at any time to the processing of your Personal Data 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 is necessary for the establishment, exercise, or defence of legal rights, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to withdraw consent You may withdraw your consent for Us processing Personal Data about you at any time. Withdrawal does not affect the lawfulness of any processing carried out before that withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, this includes any supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data. EU and member state law 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 additional months, depending on the complexity or volume of requests. We will notify you of any extension, and 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. However, if a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of processing the request or notifying you of the action taken. 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 suitable proof of identity.