Privacy Policy

1. The Scope

1.1 This policy outlines the types of Personal Data the Company collects about individuals, how that information is processed, when it may be shared with third parties, and the measures taken to keep it secure.

1.2 This Policy applies to information relating to an identified or reasonably identifiable individual. An identifiable individual is someone who can be identified either directly or by reference to other information we hold or can reasonably access.

1.3 In this Policy, "processing" refers to any activity that involves the use or collection of Personal Data, including the handling, organisation and storage of Personal Data.

1.4 Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly collect or request information from anyone under the age of 18, and we do not knowingly permit them to use our services. If we become aware that we hold information about a child, we will delete it as soon as reasonably possible.

2. What Personal Data Do We Have on You

2.1 When you use the service and its channels, or visit our website, we collect Personal Data. In some circumstances, we may ask you to provide your Personal Data.

2.2 In other cases, we collect your Personal Data by reviewing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide us with any personal data. However, in some circumstances, if you choose not to provide certain personal data, we may be unable to deliver the Services or allow users to access the website.

4. What Personal Data We Collect

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

4.3 Personal Data we collect from you: any personal data you choose to provide to Us when you connect to a third-party online trading platform through Us.

4.4 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 of Personal Data

5.1 The company processes your Personal Data for the purposes set out in this section and in line with the applicable legal basis.

5.3 Please contact us by email if you would like further information about the processing required to protect legitimate interests.

5.4 The following sets out the reasons and legal bases 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 that support our operations, including hosting and storage providers, IP address information services, and user experience analytics providers.

6.2 You may also request that we provide specific Personal Data relating to you to third-party trading platforms. In these circumstances, we will share the Personal Data you have provided to Us with those third-party trading platforms. Any use of your Personal Data will be governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners where necessary. This helps the Company access the resources it needs to enhance and improve the products and services it provides to its customers.

6.4 Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other relevant authorities.

6.5 We may also disclose your Personal Data to prospective investors or purchasers, or to the Company’s lenders or those of any other company within the corporate group, if such a transaction proceeds (including any transfer or sale of assets owned by the Company or another group company), or as part of any merger, restructure, consolidation or insolvency process involving the Company or any other business in the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, including advertising providers that display ads on our website and analytics providers. These companies may also use cookies or other technologies.

7.2 Cookies are small text files stored on your device each time you visit or use the website. They help us collect information about your preferences and browsing activity so we can enhance your experience, remember your settings, and tailor products and services that may be relevant to you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain there only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period after your browser is closed. They help the Website recognise you as a returning user and allow you to access the website again more easily.

7.5 However, please note that if this occurs, some or all of the Website’s functions and features may not operate as expected.

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

8. Retention of Personal Data

8.1 The Company will keep your Personal Data for as long as needed to carry out the purposes for which it is processed, as set out in this Policy, or for longer where permitted under applicable law, regulations, internal policies, or relevant orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing 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 (that is, your personal data may be disclosed to overseas recipients or international organisations). The Company takes all reasonable steps to protect the Personal Data you provide and to ensure individuals can exercise their rights and access effective legal remedies.

9.3 The Company can provide details of the security measures in place to protect your Personal Data when it is transferred to third countries or international organisations. Please email: support@reefvale.org

10. Security of Personal Data

10.1 We have put suitable organisational and technical measures in place to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss or alteration of Personal Data.

10.2 While we take reasonable steps to protect your Personal Data, we cannot guarantee that its security will be maintained without error. We are also not liable for any indirect, incidental or consequential loss or damage 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 circumstances beyond our control.

10.3 Where we are required by law, or due to circumstances outside our reasonable control, we may need to disclose your Personal Data to third parties, including government or regulatory authorities. In these circumstances, we are unable to control how those third parties protect your Personal Data.

10.4 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. Hyperlinks to Third Party Websites

11.1 The website may include links to third-party websites and applications. These websites and applications are not controlled or monitored by the Company. We are not responsible for how those websites or applications collect or process Personal Data. This Policy does not apply to any actions taken through those websites or applications.

11.2 Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also suggest considering this before providing any Personal Data.

12. Modifications to This Policy

12.1 We may update this Policy at any time. If we make any changes, we will notify you by publishing the revised Policy on our website.

12.2 We may also notify you of any material changes to this Policy using the methods we consider appropriate, and we will publish a notice on our website.

12.3 Unless stated otherwise, any changes will take effect once the updated Policy has been published.

13. Your Rights

13.1 You may ask us to confirm the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer require. You may also request that we limit the types of processing applied to your personal information.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise any of your rights, please email the address below.

13.3 Access rights You have the right to confirm whether the Company is processing your Personal Data. Where it is, you may request access to that 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 electronically. This right of access must not adversely affect the rights and freedoms of others. If your request would prejudice another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can comply.

13.4 Right to rectification The Company may correct any inaccurate Personal Data. You also have the right to request that any incomplete Personal Data relating to you be corrected, taking into account the purpose for which it is being processed.

13.5 Right to Erasure This right applies in the following circumstances: (a) Personal Data are no longer needed for the purpose for which they were collected or otherwise processed; (b) You withdraw your consent and there is no other legal basis for processing; (c) You object, at any time and for reasons relating to your particular circumstances, to the processing of your Personal Data where that processing is based on legitimate interests pursued by Us or by a third party; (e) Personal Data have been processed unlawfully; or (f) 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 requiring processing under applicable law; or (b) for the establishment, exercise or defence of legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict how your Personal Data is processed. Where you request a restriction, your Personal Data may then only be retained with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another individual, or where there is an important public interest reason under applicable law.

13.7 Right to data portability Where processing is carried out by automated means and relies on your consent or a contract to which you are a party, you have the legal right to receive the Personal Data you have provided to the Company and to have that data transferred directly to another controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. This right does not override the rights or freedoms of others.

13.8 Right to object You may object at any time to the use of your Personal Data where the processing is based on the legitimate interests of the Company or a third party. This right also applies to profiling carried out on the basis of those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue to process it unless you can show that your rights, freedoms or interests override those grounds, or that the processing is required for the establishment, exercise or defence of legal claims. 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 withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the legality of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to make a complaint to the relevant supervisory authority. In some cases, applicable laws and regulations may limit your rights in relation to your Personal Data, as outlined in this section 13.

13.10 We will provide the information you request in accordance with your rights under 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 of the request and the number of requests received. If an extension applies, we will notify you within one month of receiving your request and explain the reasons for the delay.

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

13.12 If we have any concerns about the identity of the individual who submitted your request, we may ask the person making the request to provide reasonable proof of identity.