Privacy Policy

For clarity and transparency about how we collect and handle your personal information:

We want you to be able to make informed decisions about how your Personal Data is collected and used. That’s why we’ve set up this website. To support this, we use a range of approaches to give you clear, relevant information about our handling of Personal Data.
If we think you need more specific information, we’ll provide it at the appropriate time.
If you have any questions, please contact us and we’ll do our best to assist, subject to any legal requirements. You can reach us by email at: info@bold-capholm.com

Personal information will be used only for the purposes set out in this Policy.

We may process your Personal Data for a range of purposes, including providing you with access to the website and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the ongoing maintenance and delivery of the Services, meeting applicable legal and regulatory requirements, and carrying out administrative and business activities that enable the Services to be delivered and used.
We also process Personal Data to better understand your preferences and needs.

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

To help you exercise your rights, we have the processes and resources in place to support you. You can contact us at any time to request access to the Personal Data we hold about you. At your request, we will update or delete it, restrict or stop its use for specific or general purposes, or provide a copy to you or transfer it to another party. We will endeavour to process your request promptly.

Protect your personal information:

Although we can’t guarantee absolute security of your Personal Data, we can assure you that we continually use a range of measures and safeguards to help protect it.
Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy explains what types of Personal Data the Company collects about individuals, how it is used, when it may be shared with third parties, and the steps we take to protect it.
This Policy covers information relating to an identified or identifiable individual. An identifiable individual is someone who can be identified directly, or indirectly by combining information with other data we hold or can reasonably access.
In this Policy, “processing” refers to any activity involving Personal Data, including collecting, using, managing, organising, and storing it.
Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly collect information from, or allow the use of our services by, anyone under 18. If we become aware that we have collected Personal Data from a child, we will delete it as soon as reasonably possible.

2. What Personal Information Do We Hold About You?

When you use our services or service 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 and analysing how our services or service channels are used, or by receiving information about you from our third-party partners.

3. You’re not required to provide the company with personal information, and you’ll be informed of any consequences if you choose not to.

You’re not required to provide us with any personal data. However, in some situations, choosing not to provide certain personal data may mean we can’t deliver the Services, or it may limit users’ ability 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 about your online activity log and usage data, such as your IP address, the date and time you accessed the site, the language you selected, software crash reports, the browser type, and information about the device you used. The data we collect is not personal information and cannot be used to identify you.
Personal data we receive from you: any personal information you choose to provide when you connect, via us, to a third-party online trading platform.
Personal information you provide directly to third-party platforms to enable trading: this may include your full name, address, phone number, and email address.

5. Legal basis and reasons for processing personal data

6. Sharing Personal Data with Third Parties

The Company may share Personal Data with third-party service providers that support our operations, such as hosting and storage providers, analytics providers, and providers that process IP address information and analyse user experience.
You may also ask us to share specific Personal Data about you with third-party trading platforms. Where you request this, we will provide the Personal Data you supply to us to those third-party trading platforms. Their handling of your Personal Data will be governed by their own privacy policies, and your Personal Data may be shared with more than one trading platform.
The Company may also share Personal Data with related entities or business partners. This helps us access resources and support to improve and enhance the products and services we provide to customers.
Where necessary to protect the rights of third parties or to safeguard assets, the Company may disclose Personal Data to regulatory bodies, local authorities, or other relevant official authorities.
We may also share Personal Data about you with prospective investors or purchasers, or with lenders to the Company or any other company within the group, where this is connected to a transaction (including a transfer or sale of assets of the Company or any other group company) or forms part of a merger, restructuring, consolidation, or insolvency of the Company or any other business within the group.

7. Third-party cookies and services

We may use third-party services, such as advertising providers that display ads on our website or analytics providers. These companies may also use cookies or similar technologies.
Cookies are small text files stored on your device each time you visit or access the website. They help us understand your preferences and browsing behaviour so we can improve your experience, remember your settings, and tailor products and services that may be of interest to you. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily placed on your device and are deleted shortly after you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to come back to the website.

Types of Cookies:

We may use them depending on their intended purpose:

ONLINE TRACKING NOTICE
This service does not currently respond to Do Not Track signals.
8. Retaining your personal information

The Company will keep your Personal Data only for as long as it is needed to carry out the purposes described in this Policy, or for any longer period permitted under applicable laws, regulations, internal policies, or relevant orders.
We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer required.

9. Overseas disclosures of personal information to third countries or international organisations

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards to help prevent accidental or unlawful destruction, loss, alteration, or misuse of Personal Data.
However, we cannot guarantee that your Personal Data will always remain secure or that security measures will be free from error. To the extent permitted by law, we are not responsible for any indirect, incidental, or consequential loss arising from the use of, or unauthorised access to or disclosure of, Personal Data. This includes, without limitation, disclosure resulting from transmission errors, unauthorised access by a third party, or any other cause beyond our reasonable control.
Where required by law or where other obligations outside our control apply, we may need to disclose Personal Data about you to third parties, such as government agencies or other public authorities. In these circumstances, we cannot control the security measures applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to us online.

11. Links to third-party websites

The website may include links to third-party websites and applications. These websites and apps are not operated or controlled by the Company, and we are not responsible for how they collect, use or otherwise process Personal Data. This Policy does not apply to any actions you take on those third-party sites or apps.
If you choose to visit any third-party website or use any third-party app, we recommend reviewing their privacy policy before accessing or using their services. We also encourage you to consider carefully before providing any Personal Data to them.

12. Changes to this Policy

If you visit any third‑party websites or apps, we recommend reading their privacy policies before choosing to access or use their services. We also encourage you to consider carefully before providing them with any Personal Data.

13. Your rights regarding your personal information

You may ask us to confirm whether we are collecting and processing 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 the way we process your Personal Data.
If you are located in the EEA, please refer to this page:
These rights apply to the information you provide to us in connection with your Personal Data. To exercise any of these rights, please email us at the address listed below.
Access rights
You have the right to request confirmation as to whether we process Personal Data about you and, where we do, to access that Personal Data.
We will provide an electronic copy of the Personal Data we are currently processing. We may charge a reasonable fee for additional copies. If you request it, the information will be provided electronically.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would impact another person’s rights and freedoms, we may refuse the request or limit the extent to which we can comply.
Right to rectification
You have the right to have inaccurate Personal Data corrected. You also have the right to have incomplete Personal Data about you completed, taking into account the purposes for which it is processed.
Right to Erasure
You may request deletion of your Personal Data where: (a) it is no longer needed for the purposes for which it was collected or otherwise processed; (b) you withdraw consent and there is no other lawful basis for processing; (c) you object, on grounds relating to your particular situation, to processing based on legitimate interests relied on by us or a third party; (e) your Personal Data has been processed unlawfully; or (f) it must be deleted to comply with a legal obligation applicable to the Company.
This right does not apply where processing is necessary (a) to meet a legal obligation; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you believe your Personal Data is inaccurate, you may ask the Company to restrict processing of your Personal Data while we verify its accuracy.
Where processing is restricted, we may store your Personal Data but may only otherwise process it with your consent, to establish, exercise or defend legal rights, to protect the rights of another individual, or for reasons of substantial public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or a contract you have entered into, you have the right to receive the Personal Data you have provided to the Company and to request access to it.
Where technically feasible, you may also request that your Personal Data be transferred directly from the Company to another controller. Exercising data portability does not affect your rights under the right to erasure. Your right to data portability must not adversely affect the rights and freedoms of others.
Right to challenge
You have the right, at any time, to object to the processing of Personal Data about you where that processing is based on legitimate interests relied on by the Company or a third party, including profiling based on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing that override your rights and interests, or if processing is required to establish, exercise, or defend legal rights, we may continue processing despite your objection.
Concerning direct marketing, you have the right at any time to object to the processing of Personal Data about you.
Right to refuse 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 the relevant supervisory authority.
You may lodge a complaint with a supervisory authority responsible for protecting individuals’ rights in relation to the processing of Personal Data under applicable law.
Applicable laws may limit your rights in relation to Personal Data about you, as described in this section 13.
We will provide the information you request in connection with your rights under section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, taking into account the complexity of the request and the number of requests received. If we extend the timeframe, we will notify you within one month of receiving your request and explain the reasons for the delay.
Unless otherwise permitted under section 13, the information you request when exercising your rights under section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, particularly because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may decline to act on the request.
If we have reasonable concerns about the identity of the person making the request, the Company may ask for additional information to confirm that identity.