Privacy notice
We (also referred to as "We", "Us" or "Our") are committed to safeguarding your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://zephyrkapitholm.com (the Zephyr Kapitholm).
We will uphold the following principles:
We help you make informed choices about how your Personal Data is used and processed. We use various methods and procedures to provide clear, relevant information. If we believe you need specific details, we will share them at the appropriate time. We are also available to answer any questions about our data practices, account controls, or any applicable service limitations.
1. The scope?
This policy explains the types of Personal Data Zephyr Kapitholm collects about individuals and how that data is processed, shared with third parties, stored, and secured.
This Policy covers 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 that we hold or can access.
In this Policy, "processing" means any activity involving the collection or use of Personal Data, including organising, managing, structuring, and storing Personal Data.
Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly request or collect information from anyone under 18 or knowingly allow them to use our services. If we discover that we have collected information about a child, we will delete it as soon as reasonably possible.
2. What Personal Data Do We Hold About You?
We collect Personal Data when you access our service or service channels, or visit our website. In some cases, we may ask you to provide it. In other cases, we collect Personal Data by analysing how you use our Services or service channels, or when third-party partners share your information with us.
3. You may decline to disclose personal information to the company without consequences.
However, you are not required to provide us with any personal data. In some circumstances, choosing not to provide certain personal data may limit our ability to provide the services or may prevent users from accessing the website.
4. What types of personal data may we collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity logs and traffic data (including your IP address, access date and access time), the language you use, software crash logs, browser type, and details about the device you use to access the service. The information we collect is not considered personal data and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide to Us when you connect, through Us, to a third-party online trading platform.
Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, telephone number, and email address.
5. Transparency and Purposes for Processing Your Personal Data
The Company processes your Personal Data for the purposes described in this section, using transparent data-handling and security practices.
The Company uses Personal Data concerning you only where there is a clear and appropriate reason. The following explains when the Company may process your Personal Data:
- You have consented to our processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to pursue legitimate interests, such as improving Our Services or defending legal claims.
- Processing follows clear service standards.
Contact us by email for more details on how we process information and the measures we use to protect it.
Below is a summary of why we may use the information you provide, including relevant account, service, and security purposes involving Personal Data.
Scope, Transparency
1. At your request, we may collect Personal Data from you and share it with third-party providers to help you access digital trading services. We will do this only when you ask us to arrange it.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns about the Services, we may need Personal Data.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed only when necessary for account administration, platform security, and clearly stated service requirements.
Processing is required to support secure, reliable account services.
4. To improve Our Services. We may use Personal Data to enhance Our Services, including, among other things, crash and malfunction reports that we collect in connection with the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To conduct and manage activities that support the operation of Our Services. These may include back-office functions, business development, strategic decision-making, internal review processes, and related activities.
Processing is necessary for the legitimate interests of the Company or a third party.
7. We conduct analysis, including statistical analysis, and use various analytical techniques, including statistical methods, to support decisions on a range of matters.
Processing is necessary for the legitimate interests of the Company or a third party.
8.
To safeguard our assets, rights, and interests, as well as those of third parties, we have established processes to pursue and defend legal claims.
We may process Personal Data where necessary to protect our rights, interests, and assets, or those of third parties, in accordance with relevant agreements, conditions, terms, and policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, including hosting and storage providers, IP address data services, and user experience analysis.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will provide those platforms with the Personal Data you have supplied to us. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with related entities or business partners. This may provide the Company with resources that help enhance and improve the products and services offered to customers.
Where necessary to safeguard third-party rights or assets, the Company may apply appropriate account controls, security practices, and transparent data-handling procedures.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or another company within the group where a relevant transaction is being considered. This may include the transfer or sale of assets belonging to the Company or another group company, or form part of any merger, restructuring, consolidation, or insolvency involving the Company or another business within the group.
7. Cookies and third-party services
We may use third-party services, including companies that provide advertising on our website or analytics services. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. They collect information about your preferences and browsing habits to improve your user experience, remember your choices, and tailor products and services that may interest you. Cookies are also used for statistical and analytical purposes.
Some cookies we use are session cookies. They are temporarily downloaded to your device and remain there until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to revisit and use the website.
Cookie Categories:
We may use them for their intended purpose:
1. Cookies are essential for this site
These cookies are necessary to access the features you requested and navigate our website. They help provide the information, products, and services you asked for.
They are also required for your device to download and stream data, allowing you to navigate the website, use its features, and return to pages you previously visited.
Cookies collect personal data, such as your username and most recent login date, to confirm you are logged in to the site. Session Cookies are deleted when you close your web browser.
2. Functional Cookies
Cookies help us recognise you each time you visit our site and remember your settings and preferences.
Cookies collect personal data, such as your username and most recent login date, to confirm you are logged in to the site. Session Cookies are deleted when you close your web browser.
3. Performance cookies
We use cookies to collect statistical data on site performance and improve it. They also help us analyse how our website is used.
Cookies store anonymous data that is not linked to an identified or identifiable natural person. Some are deleted when you close your browser, while others may remain on your device indefinitely.
Cookies are blocked or have been removed
To block or remove cookies, you need to update your browser settings. Use the links below for guidance in some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, some or all of the Website's functions and features may not work as expected if this happens.
ONLINE TRACKING NOTICE
This service currently does not respond to Do Not Track signals.
8. The retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfil the purposes for which it is processed, as described in this Policy, or longer where needed to support account controls, security practices, and service standards.
We will share your information with third-party trading platforms for 12 months. If you agree, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we retain to confirm it is still needed.
9. Transfers of personal information to a third country or international organisation
Your Personal Data may be transferred to other countries. This means it may be sent to a third country outside your country of residence, or to an international organisation or jurisdiction. The Company takes appropriate steps to safeguard the Personal Data you provide and help ensure that data users can exercise their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that maintains appropriate safeguards for Personal Data, supported by transparent security practices, clear data-handling standards, and suitable controls to protect information throughout the transfer process.
- The transfer is governed by a clear agreement between the relevant public entities or authorities, with transparent terms, defined controls, and service standards.
- The transfer was handled under established data protection clauses and security practices designed to support responsible handling of personal information. We use transparent data-transfer procedures, documented controls, and service standards to help safeguard information processed across borders.
The Company 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, please email info@zephyrkapitholm.com
10. Personal Data Security
We apply appropriate organisational and technical precautions to protect Personal Data. These measures are designed to reduce the risk of accidental or unlawful destruction, loss, alteration, or unauthorised access.
However, we cannot guarantee or warrant that your Personal Data will always remain secure or error-free. We cannot be held responsible for intangible, incidental, or consequential losses arising from the use or disclosure of Personal Data, including disclosure caused by transmission errors, unauthorised third-party access, or circumstances beyond our reasonable control.
In certain circumstances beyond our control, we may need to share Personal Data concerning you with third parties, such as service providers or public authorities. Where this occurs, we cannot control the security measures those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of Personal Data you transmit to Us online.
11. Links to websites operated by third parties
Our website may include links to third-party websites and applications. These sites and apps operate independently and are not controlled by the Company. We are not responsible for how they collect or process Personal Data, and this Policy does not apply to any activity carried out through them.
Before accessing or using any third-party website or app, We recommend that you review its privacy policy and practices. We also suggest that you consider them carefully before providing any Personal Data.
12. Changes to this Policy
When visiting third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. We also suggest carefully considering whether to provide them with any Personal Data.
13. Your rights over your personal information
You may ask us to confirm whether Personal Data relating to you is being collected, correct any inaccuracies, and delete Personal Data that We no longer require. You may also ask us to restrict certain types of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide and other Personal Data relating to you. You may exercise your rights by sending an email to the address below.
Access rights
You may ask the Company to confirm whether your Personal Data is being processed. If it is, you may request access to that Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The information will be provided electronically if you request that format.
Your right to access Personal Data must not adversely affect the rights and freedoms of others. If a request could harm another person’s rights or freedoms, the Company may refuse to comply with it or limit the information provided.
Right to rectification
You may ask the Company to correct inaccurate Personal Data. You may also request completion of incomplete Personal Data concerning you, taking account of the purpose for which it is processed.
Right to erasure
You may request erasure where: (a) Personal Data is no longer required for the purpose for which it was collected or processed; (b) You withdraw consent and there is no other lawful basis for processing; (c) You object, for reasons relating to your circumstances, to the processing of Personal Data based on legitimate interests pursued by Us or a third party; (e) Personal Data has been processed unlawfully; or (f) Personal Data must be deleted to meet an applicable legal obligation.
This right does not apply where processing is necessary: (a) to meet a legal obligation requiring processing under European Union or Member State law; or (b) to establish, exercise or defend legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing while the information is checked.
Where you ask for processing to be restricted, Personal Data may generally only be stored unless you provide consent, or where it is needed to establish, exercise or defend legal claims, protect the rights of another person, or address an important public-interest matter within the European Union or a Member State.
Right to data portability
Where processing is automated and based on your consent or a contract with you, you may request the Personal Data you have provided to the Company in a structured, commonly used, and machine-readable format.
You may also ask for your Personal Data to be transferred directly from the Company to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure. Data portability must not adversely affect the rights or freedoms of anyone else.
Right to object
You may object at any time, for reasons relating to your circumstances, to the use of Personal Data concerning you where processing is based on legitimate interests pursued by the Company or a third party. This includes profiling based on those interests. We may continue processing where there are compelling legitimate grounds that outweigh your rights, freedoms, and interests, or where processing is required to establish, exercise, or defend legal claims.
In relation to direct marketing, You may object at any time to the processing of Personal Data concerning you, including related profiling.
Right to withdraw consent
You may withdraw your consent to Us processing Personal Data about you at any time. This will not affect the validity of processing carried out on the basis of your consent before it was withdrawn.
You may raise a complaint directly with Us using the contact details provided below.
We aim to handle privacy concerns clearly and fairly, explain how your Personal Data has been used, and provide an appropriate response to issues raised about its processing.
In certain circumstances, European Union or Member State laws may limit the rights relating to your Personal Data described in this section 13.
We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two further months where necessary, depending on the complexity and number of requests. Within one month of receiving your request, We will notify you of any extension and explain the reasons for it.
Unless otherwise provided in section 13, information requested under your rights in section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, particularly where requests are repeated, We may charge a reasonable fee to cover the administrative cost of providing the information or taking the requested action. We may also decline to act on the request.
If the Company has reasonable doubts about the identity of the person making a request, it may ask for additional information needed to confirm that person’s identity.