Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects on individuals, and how it processes, shares with third parties, and secures that data.

1.2 This Policy relates to information concerning an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through a combination of additional information we hold or are reasonably able to access.

1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data, including its management, organisation, and storage.

1.4 Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18 years of age. We do not knowingly permit such individuals to use our services. Should we become aware of any information held about a child, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services and channels, or visit our website, we collect Personal Data. We may also request your Personal Data in certain circumstances.

2.2 In other instances, we collect your Personal Data by analysing how our Services or service channels are used, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. However, in certain circumstances, choosing not to do so may prevent Us from offering the Services or restrict access to the website.

4. What Personal Data We Collect

4.2 The information collected is not private and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you provide to us of your own accord when you connect with a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 Your personal data is processed by the company for the purposes set out in this section, and in accordance with the applicable legal basis.

5.3 Contact us by email for further details on the processing required to protect legitimate interests.

5.4 Below is a list of 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 companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analysis.

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

6.3 The Company may share Personal Data with related entities or business partners. This enables the Company to access the resources needed to enhance and improve the products and services provided to its 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.

6.5 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 the event that such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of 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 Third-party services, such as advertising providers or analytics companies, may be used on our website. These companies may also make use of cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve your experience, remember your settings, and personalise the products and services you may be interested in. Cookies are also used for statistical and analytical purposes.

7.3 Certain cookies we use are session cookies. These are temporarily downloaded to your device and remain active only until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are used to help the Website recognise you as a returning user and allow you to return to the website.

7.5 However, please be aware that some or all of the Website's functions and features may not work as expected if this happens.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as is necessary to fulfil the purpose for which it was collected, as described in this Policy, or for longer periods where permitted by applicable law, regulation, or policy.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue to share your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to ensure it is no longer required.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country or to international organisations). The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects are able to assert their rights and access effective legal remedies.

9.3 The Company can provide information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please send an email to: support@sparrowgewinode.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 In the event of legal or other obligations beyond our control, we may be required to share your Personal Data with third parties, such as public authorities. We cannot control how your Personal Data is handled or secured by those third parties in such circumstances.

10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.

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 supervision of the Company. We are not responsible for the collection or processing of Personal Data by such sites or applications. This Policy does not apply to any actions carried out through them.

11.2 When visiting any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you carefully consider any Personal Data you provide to 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 In addition, when we make significant changes to this Policy, we will endeavour to notify you using appropriate methods and will publish an announcement on our website.

12.3 Unless otherwise specified, any amendments will take effect upon publication of the revised Policy.

13. Your Rights

13.1 You have the right to request that we verify the accuracy of Personal Data collected about you, rectify any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to you in respect of the Personal Data you provide. You may request to exercise these rights by sending an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If it is, you are entitled to access your 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 data will be made available electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights or freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data relating to you be corrected, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to process; (c) You object at any time, based on a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet the company's lawful obligations. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that requires processing 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 limit its processing. Where you request such a restriction, your Personal Data may only be retained with your consent, in order to establish, exercise, or defend legal rights, to protect the rights of another natural person, or where there is a matter of significant public interest within the European Union or a Member State.

13.7 Right to data portability If the processing is carried out by an automated system and is based on consent or a contract to which you are a party, you have the legal right to access and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by the exercise of your right to data portability. The right to data portability does not interfere with the rights or freedoms of any other person.

13.8 Right to challenge You have the right to object, at any time, to any use of your Personal Data that is based on the legitimate interests of the Company or a third party. This right is not limited to profiling based solely on those legitimate interests. Where we are able to establish compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests outweigh ours, or that the processing affects the exercise, establishment, or defence of legal rights. In relation to direct marketing, you have the right to object at any time to the processing of your Personal Data.

13.9 Right to refuse consent You may withdraw your consent for Us processing Personal Data about you at any time. This will not affect the legality or lawfulness of any processing that was carried out based on your consent prior to its withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. You may submit a complaint 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 its Member States may limit your rights in relation to Personal Data concerning you, as set out in this section 13.

13.10 We will provide you with the requested information, in accordance with the rights set out in section 13 of this agreement, within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

13.11 Provided it does not conflict with the provisions of section 13 of the law, any information you request in exercise of your rights under section 13 will be provided free of charge. If a request is unjustified or excessive, particularly where requests are repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the action requested. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable means of identification.