Privacy Policy

1. The Scope

1.1 This policy describes the types of personal data the Company collects about individuals, and how it processes, shares with third parties, and secures that data.

1.2 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 indirectly 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 organization, structuring, and storage.

Our services are intended for general audiences and are not available to anyone under the age of 18. We do not knowingly collect information from individuals under 18, and we do not permit them to use our services. If we become aware that such information has been collected, 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 or service channels are used, or by receiving your information from our 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

4.2 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 voluntarily provide to us when you connect with a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trades, including 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, in accordance with the applicable legal basis.

5.3 For details on the processing carried out to protect legitimate interests, contact us by email.

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, IP address data handlers, and user experience analytics firms.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transmit the relevant Personal Data you have provided to us directly to those platforms. Your Personal Data on those platforms is governed by their respective privacy policies. Your Personal Data may be shared with more than one third-party trading platform.

6.3 The Company may share Personal Data with related entities or business partners to support the enhancement and improvement of its products and services.

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 involving the transfer or sale of Company assets, a merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third parties — such as advertisers and analytics providers — who operate on our website and may use cookies or similar tracking technologies.

7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your preferences and browsing habits, maintain your settings, and tailor the products and services presented to you. Cookies are also used for statistical and analytics purposes.

7.3 We use two types of cookies: session cookies and persistent cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognize you as a returning user, allowing you to return to the Website more seamlessly.

7.5 Please note that disabling certain functions may cause some or all Website features to behave unexpectedly.

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 fulfill the purposes described in this Policy, or for longer periods as 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 do so for a further 12 months.

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

9. International Transfers

Your personal data may be transferred to other countries or shared with international organizations. The Company takes 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@broadreturnifery.com

10. Security of Personal Data

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

We cannot guarantee that the security of your Personal Data will be maintained without error. We are not liable for any 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 control.

10.3 In some circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over how those third parties protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be fully secured. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how those sites or applications collect or process personal data. This Policy does not apply to actions taken through such third-party sites or applications.

Before accessing or using any third-party websites or apps we recommend, read their privacy policies. Only provide your personal data to them once you are comfortable with how it will be handled.

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 significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless otherwise specified, amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You may request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types or scope of processing applied to your personal information.

If you are an EEA resident, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of your Personal Data upon request and may charge a reasonable fee for additional copies. This right must not conflict with the rights and freedoms of others. Where fulfilling 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 rectify any inaccurate Personal Data it holds. You have the right to request the correction of incomplete Personal Data concerning you, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request the deletion 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 no other legal basis for processing exists; (c) you object to the processing of your Personal Data based on a reason specific to your situation, where processing is based on legitimate interests pursued by Us or a third party; (e) the Personal Data are unlawfully processed; or (f) deletion is required to fulfil 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 limit its processing of that data. If 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 for reasons of significant 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 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. This right does not adversely affect the rights or freedoms of others.

13.8 Right to challenge You may 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 demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where the processing relates to the establishment, exercise, or defense of legal claims, we may continue to process your Personal Data notwithstanding your objection. Concerning direct marketing, you have the right at any time to object to the processing of your Personal Data.

13.9 Right to refuse consent You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal. You have the right to lodge a complaint with your relevant supervisory authority. Within the European Union, you may submit a complaint to a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data. Applicable European Union and Member State laws may limit your rights regarding your Personal Data, as described in this section 13.

We will provide the information requested under Section 13 of this agreement within one month of receiving your request. If the complexity or volume of requests requires additional time, this period may be extended by up to two months. We will notify you of any such extension, along with the reasons, within one month of receiving your request.

Subject to section 13 of the law, information provided in response to your rights requests under that section will be made available at no cost. Where a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

13.12 If we have reasonable grounds to question the identity of the person submitting a request, we may require that individual to provide adequate means of verification.