Privacy Policy

1. The Scope

This policy explains what personal data the Company collects about individuals, and how that data is processed, shared with third parties, and secured.

This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified through a combination of additional information we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we knowingly permit them to use our services. If we become aware that we hold information relating to a minor, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect personal data. In certain instances, we may request personal data from you directly.

In some 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, withholding it may prevent us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

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

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

4.4 Personal information you provide directly to third-party platforms to facilitate trading 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 set out in this section, in accordance with the applicable legal basis.

5.3 Contact us via email for further details on the processing carried out to protect legitimate interests.

5.4 The following outlines 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, as well as companies that analyse IP address information and user experience data.

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 accordingly. Your Personal Data shared in this way is governed by the privacy policies of the respective third-party trading platforms. 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 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.

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 connection with a transaction such as the transfer or sale of company assets, a 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 service providers, such as advertising partners and analytics companies, who operate on our website and may use cookies or similar tracking technologies.

7.2 Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytics 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 your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you resume your session.

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

Online Tracking Notice: This service does not currently support 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 required or permitted by applicable law, regulations, or orders.

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

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or shared with international organisations. We take all necessary steps to protect your personal data and ensure you retain the right to assert your 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@dawnanlagholm.com

10. Security of Personal Data

We have implemented appropriate organisational and technical 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 also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including where disclosure results from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

In some circumstances, we may be legally or otherwise obligated to disclose your personal data to third parties, including public authorities. We have no control over how those third parties handle or secure your personal data once it has been disclosed.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 Our website may contain links to third-party sites and applications. These sites and applications are not operated or supervised by the Company. We are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.

Before visiting any third-party website or app, we recommend reading their privacy policy. Be mindful of any personal data you choose to share with them.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be reflected in the updated Policy posted on our website.

12.2 When we make significant changes 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 verification of the accuracy of your Personal Data we hold, to have any inaccuracies corrected, and to request deletion of Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.

If you are a resident of the EEA, 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 applicable, you have the right to access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its compliance with that request.

13.4 Right to rectification We may correct inaccurate Personal Data held about you. You have the right to request that incomplete Personal Data be rectified, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request the 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 to the processing of your Personal Data based on legitimate interests pursued by Us or a third party, and no overriding legitimate grounds exist; (e) the Personal Data are 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 requested, 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 reason 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 the Personal Data you have provided to 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 your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of your Personal Data where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. If 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 rights, we may continue to do so. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to withdraw consent You may withdraw your consent for Us processing Personal Data about you at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent prior to that withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. Within the European Union, you may lodge a complaint with the supervisory authority established by a member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that the laws of the European Union and its member states may limit the rights described in this section 13.

We will respond to requests made under the rights set out in section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide suitable means of identification.