Privacy Policy
We (also known as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is designed to inform you of how we collect and store the information you provide through the website https://keenequitondary.com (the Keen Equitondary ).
The following principles will be upheld:
We want to ensure you are well-informed when it comes to how your Personal Data is used and processed. We use a variety of methods to provide you with relevant information, and where specific details are needed, we will share them with you at the appropriate time. We are always happy to address any questions you may have regarding any limitations imposed by law.
1. The Scope?
This policy describes the types of Personal Data that Keen Equitondary collects about individuals, and how it processes, shares with third parties, and secures that data.
This Policy applies to information that relates to an identified or identifiable natural person — that is, someone who can be identified directly or through a combination of additional information we hold or are able to access.
The Policy defines "processing" as any operation involving the use or collection of Personal Data, including its management, organization, and storage.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we have inadvertently collected information from a minor, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and 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 analyzing how our services and service channels are used, or by receiving your information from our third-party partners.
3. There is no requirement to share personal information with the company, nor any consequences for choosing not to do so.
You are not required to provide us with any personal data. However, in certain circumstances, choosing not to do so may limit our ability to deliver our Services or restrict your access to the website.
4. What Personal Data Do We Collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity log, data about your traffic (including IP address, date of access, time of access, and date of visit), the language you used, software crash logs, the type of browser used, as well as information about the device you utilized. This information is not personal in nature and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide to Us when you connect with an online trading platform of a third party through Us.
Personal information you provide directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.
5. The Legal Basis and Reasons for Processing Personal Data
Your personal data is processed by the Company for the purposes described in this section, and in accordance with the applicable legal basis.
Without a legal basis, the Company is not permitted to use your personal data. The legal grounds upon which the Company may rely to process your personal data are as follows:
- You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we may share it with a third-party trading platform.
- The Company or a third party may need to process your information to support their legitimate interests — for example, to improve Our Services or to defend against legal claims.
- Processing is required to comply with a legal obligation.
Contact us by email for more details on the processing required to protect legitimate interests.
Below is a list of the reasons and legal grounds under which we may use the personal information you provide us with. Personal Data.
Scope, Legal Basis
1. To share your personal information with third-party companies at your request in order to facilitate access to digital trading. If you request this, we may collect your Personal Data to forward it to the relevant third-party companies.
You have provided your consent to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions, or concerns. Personal Data is required to help us respond to any questions you may have regarding the Services.
Processing is required to serve the legitimate interests of the Company or those of a third party.
3. Personal Data may be processed to fulfil legal requirements, including administrative, judicial, or other applicable legal obligations.
To meet legal obligations, processing is required.
4. We may use your Personal Data to improve and enhance Our Services. This includes, but is not limited to, crash reports and malfunction data collected in connection with the Services.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
6. To carry out and manage activities that align with the requirements of Our Services. This includes back-office operations, business development, strategic decision-making, oversight mechanisms, and related functions.
Processing is necessary to support the legitimate interests of the Company or those of a third party.
7. To conduct analysis, including statistical analysis, and to support decision-making on various matters, we employ a range of analytical techniques (including statistical methods).
Processing is required to serve the legitimate interests of the Company or those of a third party.
8.
To protect our assets, rights, and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims.
Personal Data may be processed by us to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any related conditions, terms, or policies.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analytics.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you have shared with us to those third-party trading platforms. The use of your Personal Data will be governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources necessary to enhance and improve the products and services offered to its customers.
In cases where it is necessary to protect the rights or assets of third parties, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, in the event that a relevant transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Cookies and Third-Party Services
Third-party services, such as advertising providers or analytics companies, may be used in connection with our website. These companies may also make use of cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to enhance the user experience, remember your settings, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for the duration of your browsing session, expiring once you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period of time after you close your browser. They help the website recognize you as a returning user and make it easier for you to pick up where you left off.
Types of Cookies:
They may be used by us based on their purpose:
1. Cookies Are Required
These cookies are required to give you access to the features you've requested and to navigate our website. They are used to deliver the information, products, and services you've asked us to provide.
They are also necessary for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you've previously visited.
Cookies collect Personal Data, such as your username and last login date, to verify that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
2. Functionality Cookies
Cookies allow us to recognize you each time you visit our site and to save your settings and preferences.
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
3. Cookies for performance
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to conduct analysis on our website.
Cookies store anonymous data that is not associated with any identified or identifiable individual. Session cookies are removed when you close your browser, while other cookies may remain valid indefinitely.
Cookies are blocked or removed
To prevent or delete cookies, you'll need to adjust your browser's settings. Below are links to guide you through the process for some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that if this occurs, some or all of the Website's features and functions may not perform as expected.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. The Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected, as outlined in this Policy, or for longer periods as permitted by applicable laws, regulations, and orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we hold to ensure it is no longer retained than necessary.
9. Transfers of Personal Information to a Third-Party Country or International Organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — one other than your country of residence — or to international organizations and jurisdictions). The Company takes all necessary steps to safeguard the personal data you provide and to ensure that users are able to exercise their rights and access effective legal recourse.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses can be reviewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. To learn more, please send an email to info@keenequitondary.com
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data. This includes safeguarding against accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorized access by a third party, or any other cause beyond our control.
In the event of legal or other obligations beyond our control, we may be required to share Personal Data about you with third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by third parties in such circumstances.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to us via the internet.
11. Links to Third-Party Websites
Links to third-party websites and applications may be found on this website. These third-party sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these websites or applications. This Policy does not apply to actions taken through such sites or applications.
When visiting any third-party websites or applications, we recommend reviewing their privacy policies before choosing to access or use them. We also encourage you to exercise caution when sharing any Personal Data with them.
12. Amendments to This Policy
When visiting any third-party websites or apps, we recommend reviewing their privacy policies before choosing to access or use their services. We also encourage you to carefully consider what Personal Data you share with them.
13. Your Rights Regarding Your Personal Information
You have the right to request that we verify the accuracy of the Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope and types of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, please send a written request to the email address below.
Access rights
The Company can verify whether your Personal Data is being processed. If it is, you are entitled 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. Data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights or freedoms, the Company may decline or limit its ability to fulfil it.
Right to rectification
The Company is required to correct any inaccurate Personal Data. You are entitled to request that incomplete Personal Data about you be rectified, taking into account the purpose for which it is being processed.
Right to Erasure
The following grounds may apply: (a) Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or a third party; (e) Personal Data has been unlawfully processed; 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 fulfil a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
If you request a restriction, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.
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 format.
You may request that your Personal Data be transferred directly from the Company to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure, nor does it infringe upon the rights or freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data about you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those legitimate interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is not necessary for the establishment, exercise, or defence of legal claims, we will cease processing.
Regarding direct marketing, you have the right at any time to object to the processing of Personal Data about you.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. Withdrawing consent will not affect the lawfulness of any processing that was carried out based on your consent prior to its withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
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 within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data about you, as outlined in section 13.
We will provide the requested information 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 if necessary, depending on the complexity and volume of requests. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.
Subject to the provisions of section 13, information provided in response to a request made under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where requests are repetitive, we may charge a reasonable fee to cover administrative costs, or we may decline to act.
If we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to verify their identity.