Privacy Policy

1. The Scope

This policy explains what Personal Data the Company collects about individuals, 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 identified directly, or through a combination of additional information we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" means 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, and we do not permit such individuals to use our services. If we become aware that we hold data 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 instances, we may also request personal data directly from you.

2.2 In other cases, we 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, choosing not to do so may prevent us from delivering the Services or restrict your access to the website.

4. What Personal Data We Collect

The information collected is not personally identifiable and cannot be used to identify you.

4.3 Personal data you provide to us: any personal data you choose to share when connecting to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade 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 described in this section, under the applicable legal basis for each purpose.

For more information on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following sets out 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 service providers, including hosting and storage providers, IP address data processors, and user experience analytics providers.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms. Your Personal Data will then be subject to their respective privacy policies. Please note that your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with related entities or business partners 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 relevant official authorities.

We may also share your personal data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of assets — 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 We may work with third-party services, such as advertising providers and analytics companies. These third parties may also use cookies or similar technologies on our website.

7.2 Cookies are small text files placed on your device when you visit the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytical purposes.

Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after the browser is closed. These help the Website recognise you as a returning user and allow you to resume your session.

7.5 Please note that disabling cookies may cause some or all Website features to not function as expected.

Online Tracking Notice: This service does not currently recognise 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 longer periods where permitted by applicable law, regulation, or order.

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

8.3 We periodically review the Personal Data we hold to determine whether it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect the personal data you provide and to ensure that individuals retain the ability to exercise their rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@capitalholdste.com

10. Security of Personal Data

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

We cannot guarantee that your Personal Data will be kept secure at all times or free from 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 reasonable control.

10.3 Where legal or other obligations beyond our control require it, we may need to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over how those third parties handle the security of 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

Our website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

11.2 When visiting any third-party websites or apps, read their privacy policies before choosing to access or use them. Exercise caution when sharing any personal data with those third parties.

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 When significant changes are made to this Policy, we will notify you through appropriate channels and publish 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 that we verify the accuracy of Personal Data we hold about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal data.

If you are an EEA resident, 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 at the email address below.

13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where such processing is confirmed, 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. Data will be provided electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You have the right to request that incomplete Personal Data be rectified, taking into account 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 necessary for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation 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 request that the Company restrict its processing. Where such a restriction is in place, 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 substantial public interest 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 your Personal Data held by 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 is without prejudice to the rights and freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you 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 claims, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.

13.9 Right to withdraw consent You may withdraw your consent for Us processing Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may also appeal 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 your Personal Data, as set out in this section 13.

We will provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and volume of requests received. You will be notified of any extension, along with the reasons for it, within one month of your request.

Subject to section 13 of the law, information provided in response to a request made under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — in particular where requests are 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.

13.12 If we have doubts about the true identity of the person submitting a request, we may ask them to provide reasonable verification of their identity.