Privacy Policy

To ensure full transparency about how we collect and process your personal information:

We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we created this website. To support this, we use different methods and processes to give you clear and relevant information about the use of Personal Data.
Where we believe you need specific details, we will provide that information at the appropriate time.
We are available to answer any questions you may have and to provide any clarification you need, subject to applicable law. You can reach us by email at the address below: info@elwyn-datamere.com

Personal Data will only be used for the purposes outlined in this Policy.

We may process your Personal Data for several purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, meeting applicable legal and regulatory requirements, and carrying out administrative and business operations necessary for the provision and use of the Services.
We also process Personal Data to better understand your preferences and needs.

To access important tools that help protect your rights in relation to Personal Data:

To support the exercise of your rights, we have dedicated significant resources to this process. You can contact us at any time to request access to the Personal Data we hold about you. We can correct or delete it, restrict how it is used for specific or general purposes, and transfer the information to you or to a third party. We will do our best to honour your requests.

Keep Your Personal Data Secure:

Although we cannot guarantee absolute security for your Personal Data, we remain committed to using a range of measures and safeguards to help keep your Personal Data protected.
Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy explains the kinds of Personal Data the Company collects from individuals, how that data is processed, shared with third parties, protected, and otherwise handled.
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 by reference to other information we hold or can reasonably access.
In this Policy, "processing" means any activity involving the collection or use of Personal Data. This includes organising, structuring, storing, and managing Personal Data.
Our services are intended for a general audience and are not meant for anyone under the age of 18. We do not knowingly collect information from anyone below 18 years of age, and we do not knowingly permit such persons to use our services. If we become aware that we have collected information relating to a child, we will delete it as promptly as possible.

2. What Personal Data Do We Hold About You?

When you use our services and channels or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data directly. In other cases, we collect it by monitoring how our services and channels are used or by receiving your information from our third-party partners.

3. You are not required to provide the company with your personal information or disclose the consequences.

However, you are not required to provide us with any personal data. In some cases, if you choose not to provide certain personal data, we may be unable to offer the Services or users may be unable to access the website.

4. What Personal Data do we collect? When you visit our website, we may collect the following personal information:

This includes details of your online activity records, traffic data (including your IP address, date and time of access), the language you used, software error logs, the type of browser used, and information about the device you used. The information collected is not 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 with a third-party online trading platform through Us.
Personal information you provide directly to third-party platforms to enable trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

6. Sharing of Personal Data with Third Parties

The Company may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, providers of IP address-related services, and user experience analytics providers.
You may also request that we share specific Personal Data relating to you with third-party trading platforms. In such cases, we will provide the Personal Data you have given to us to those third-party trading platforms. Their use of your Personal Data will be 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 affiliated entities or business partners where necessary. This helps the Company access the resources required to improve and expand the products and services offered to its customers.
Where it is necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to relevant regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, purchasers, or lenders to the Company or any other company within the group where a similar transaction is being considered or carried out, including any transfer or sale of assets of the Company or any other group company, or as part of any merger, restructuring, consolidation, or insolvency process involving the Company or any other company within the group.

7. Cookies and third-party services

Third-party services, including advertising providers on our website and analytics companies, may be used. These companies may also use cookies or similar technologies.
Cookies are small text files stored on your device whenever you visit or access the website. They help collect information about your preferences and browsing activity so we can improve your experience, remember your settings, and tailor the products and services that may be relevant to you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporary and are downloaded to your device for a limited time, expiring once you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for some time after you close your browser. They help the Website recognise you as a returning user and make it easier for you to access the website again.

Types of Cookies:

We may use them depending on their purpose:

ONLINE TRACKING NOTICE
This service currently does not respond to do-not-track signals.
8. How long we keep your personal data

The Company will keep your Personal Data only for as long as needed to achieve the purpose for which it is processed, as set out in this Policy, or for any longer period allowed under applicable laws, regulations, internal policies, or lawful directives.
We will share your information with third-party trading platforms for 12 months. Where you give your consent, we will continue sharing your data for a further 12 months.
We review the Personal Data we hold on a regular basis to make sure it is no longer kept once it is no longer required.

9. Transfer of personal information to a third country or an international organisation

10. Protection of Personal Data

We have put appropriate organisational and technical measures in place to protect Personal Data. These measures are designed to prevent the accidental or unlawful destruction, loss or alteration of Personal Data.
However, we cannot guarantee that the security of your Personal Data will always be maintained without any issue. We also cannot be held liable for any indirect, incidental or consequential loss arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other circumstance outside our control.
Where required by law or where circumstances beyond our control make it necessary, we may have to disclose your Personal Data to third parties, including public authorities. In such cases, we are not responsible for the level of security applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Links to third-party websites

This website may contain links to third-party websites and applications. These websites and applications are not under the Company’s control or supervision. We are not responsible for how such websites or applications collect or process Personal Data, and this Policy does not apply to any actions taken through them.
If you choose to visit any third-party website or use any third-party application, we recommend that you read their privacy policies carefully before accessing or using them. We also advise you to consider carefully before sharing any Personal Data with them.

12. Changes to this Policy

Before visiting any third-party website or app, we recommend that you read their privacy policies carefully before deciding whether to access or use them. We also advise you to consider this before sharing any Personal Data with them.

13. Your rights regarding your personal information

You have the right to ask us to confirm whether we hold Personal Data about you, to correct any inaccuracies, and to delete any Personal Data we no longer need. You may also request that we limit how your personal information is processed.
If you are resident in the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, please send an email to the address below.
Right of access
The Company may confirm whether your Personal Data is being processed. Where this applies, you have the right 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. If you request it, the information will be provided in electronic form.
The right to access Personal Data must not adversely affect the rights and freedoms of others. Where fulfilling a request would negatively affect another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can be fulfilled.
Right to rectification
The Company may correct inaccurate Personal Data. You also have the right to request that incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
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 your consent and there is no other legal basis for the processing; (c) you object, on grounds relating to your particular situation, to the processing of your Personal Data where such processing is based on legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased in order to comply with a legal obligation binding on the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under applicable law; or (b) for the establishment, exercise, or defence of legal claims.
Restriction of processing
If you contest the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing is restricted, the Personal Data may only be stored unless you have given consent for further processing, or where processing is necessary for the establishment, exercise, or defence of legal claims, for the protection of the rights of another natural person, or for reasons of important public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company in a structured, commonly used, and machine-readable format.
You also have the right to request that your Personal Data be transmitted directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights and freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data concerning you where such processing is based on the legitimate interests of the Company or a third party. This includes profiling to the extent that it is based on those legitimate interests. If we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or where processing is required for the establishment, exercise, or defence of legal claims, we may continue processing your Personal Data.
In relation to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn.
You have the right to lodge a complaint with a competent supervisory authority.
You may submit a complaint to a supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data.
Applicable laws may limit your rights in relation to your Personal Data, as set out 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 months where necessary, depending on the nature and number of requests. If we extend the response period, we will notify you within one month of receiving your request and explain the reasons for the delay.
Unless otherwise provided under section 13 or applicable law, the information you request in exercise of your rights under section 13 will be provided free of charge. Where a request is manifestly unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information to confirm the requester’s identity.