Privacy Policy

We are committed to being transparent about how we collect and process your personal information.

We want you to be fully informed about how your Personal Data is used and processed. To support this, we use a range of methods to keep you up to date and provide relevant information at the appropriate time. If specific details are required, we will make them available when needed. We are also happy to answer any questions and provide clarification on any applicable legal limitations. You can reach us by email at the address below: info@loyaltallyholdry.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data to provide the website and connect you with third-party trading platforms (the "Services"), improve the site, protect our rights and interests, maintain and deliver the Services, meet regulatory and legal obligations, and carry out administrative and business activities in support of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights in relation to your Personal Data, you have access to a range of important tools.

To exercise your rights, please contact us at any time. You may request access to your personal data, ask us to correct or delete it, restrict or stop its processing, or arrange its transfer to you or a third party. We will accommodate your request promptly.

Protect Your Personal Data:

While no system can guarantee absolute security of your personal data, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of personal data the Company collects about natural 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 identified directly, or through a combination of additional information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its management, organisation, 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 collect information from, or permit the use of our services by, anyone under that age. Where we become aware that such data has been collected, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. Depending on the circumstances, we may request this directly from you, gather it by analysing how our services and channels are used, or receive it from our third-party partners.

You are not required to provide personal information to the company. However, withholding such information may prevent us from delivering our Services or granting you access to the website.

You are not obliged to provide us with any personal data. However, choosing not to do so may prevent us from delivering our Services or granting you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information about your online activity logs, traffic data (such as your IP address, access dates and times), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us when you connect with a third-party online trading platform through Us.
Personal information you provide to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: Service Providers: We work with third-party companies and individuals who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting, customer support, and marketing. These service providers access your personal data only to perform these functions and are contractually obligated not to disclose or use it for any other purpose. Business Transfers: If we are involved in a merger, acquisition, asset sale, or similar transaction, your personal data may be transferred as part of that transaction. We will notify you before your personal data is transferred and becomes subject to a different privacy policy. Legal Obligations: We may disclose your personal data where required to do so by law or in response to valid requests from public authorities, including courts and regulators. Protection of Rights: We may disclose your personal data where we believe it is necessary to investigate, prevent, or take action regarding potential policy violations, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation. Third-Party Links: Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing any personal data. Where personal data is transferred to third parties, we take reasonable steps to ensure it is handled securely and in accordance with this policy.

We may share Personal Data with third-party service providers who support our operations, including hosting and storage providers and user experience analytics services.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, we will share the Personal Data you have provided to us directly with those platforms. Your Personal Data shared in this way is subject to their respective privacy policies, and it may be shared with more than one trading platform.
We may share Personal Data with affiliated entities or business partners where doing so supports the development and improvement of our products and services.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share Personal Data with prospective investors, acquirers, or lenders in connection with any proposed or completed transaction involving the Company or any other entity within the group — including the transfer or sale of assets, or any merger, restructuring, consolidation, or insolvency proceedings.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. Some of these services may collect and process personal data. Where required, we obtain your consent before enabling such services. Third-party providers operate under their own privacy policies, which govern how they handle your data. We are not responsible for the data practices of third parties. We encourage you to review their policies before interacting with their services. You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Withdrawing consent may affect the functionality of certain features on our website.

We may use third-party services, such as advertising providers and analytics companies, on our website. These third parties may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit the website. They are used to record your preferences and browsing habits, improve your experience, and personalise the products and services shown to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies. These are temporary and are deleted from your device 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 navigate back to the site.

Types of Cookies:

We may use them according to their purpose.

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your 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, regulation, or order.
Your information will be shared with third-party trading platforms for a period of 12 months. Where you provide consent, sharing will continue for a further 12 months.
We review the personal data we hold on a regular basis to ensure it is not retained beyond what is necessary.

9. Transfers of Personal Data to a Third Country or International Organisation

10. Security of Personal Data We are committed to protecting your personal data and take all reasonable technical and organisational measures to safeguard it against unauthorised access, loss, misuse, alteration, or destruction. However, no method of transmission over the internet or electronic storage is entirely secure. While we strive to protect your personal data using commercially acceptable means, we cannot guarantee its absolute security. Where we have provided you with a password — or where you have chosen one — to access certain parts of our services, you are responsible for keeping that password confidential. Do not share your password with anyone. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. When determining the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and whether those purposes can be achieved by other means. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may retain and use that information without further notice.

We have taken appropriate organisational and technical measures to protect Personal Data, including against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.
Where legal or other obligations beyond our control require us to disclose Personal Data to third parties, such as public authorities, we cannot control the level of security those third parties apply to your Personal Data.
No data transmission over the internet can be guaranteed as fully secure. We cannot ensure the security of Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website contains links to third-party websites and applications. These are not operated or supervised by us, 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.
Before accessing or using any third-party website or application, we recommend reading their privacy policy carefully. We also advise caution when sharing personal data with third parties.

12. Changes to This Policy We may update this Privacy Policy from time to time. When we do, we will revise the "last updated" date at the top of this page. If changes are material, we will notify you by email or by posting a prominent notice on our website before the changes take effect. Your continued use of our services after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how we handle your personal data.

Before visiting any third-party website or app, we recommend reading their privacy policy. You should also consider carefully what personal data you share with them.

13. Your rights with respect to your personal information

You have the right to request that we verify the accuracy of Personal Data held about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also request that we restrict the scope or type of processing applied to your personal data.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, please contact us by email at the address below.
Access rights
We can verify whether your Personal Data is being processed and, if so, provide you with access to it.
We will supply an electronic copy of the Personal Data being processed. A reasonable fee may be charged for 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 another person's rights or freedoms, we may refuse or limit our response accordingly.
Right to rectification
You have the right to have inaccurate Personal Data corrected. Where Personal Data concerning you is incomplete, you may request that it be completed, taking into account the purpose for which it is processed.
Right to erasure
This right applies where: (a) the 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 relating to your particular situation, to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, for the establishment, exercise, or defence of legal claims, to protect the rights of another natural person, or on grounds of 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 party, you have the right to receive the Personal Data you have provided to us 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, and it must not adversely affect the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by us or a third party, including profiling based on those 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.
In relation to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to that withdrawal.
You also have the right to lodge a complaint with a supervisory authority established by a Member State to oversee the protection of individuals' fundamental rights in relation to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit the rights described in this section.
We will respond to requests made under this section within one month of receipt. Where necessary, having regard to the complexity and volume of requests, this period may be extended by a further two months. We will notify you of any such extension, along with the reasons, within one month of receiving your request.
Subject to the provisions of this section, information provided in response to a request will be supplied free of charge. Where requests are manifestly unfounded or excessive, in particular where they are repetitive, we may charge a reasonable fee to cover administrative costs or decline to act on the request.
Where we have reasonable doubts about the identity of the person submitting a request, we may ask for additional information to verify identity before proceeding.