Privacy Policy

To ensure full transparency about how your personal information is collected and processed:

We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we have created this website. To support this, we use a range of methods and procedures to provide you with clear and relevant information about the use of Personal Data.
If we believe you need specific details, we will provide them at the appropriate time.
We are happy to answer any questions you may have and to provide any clarification you require, subject to applicable legal limitations. You can contact us by email at the address below: info@varven-markstead.com

Personal Data will only be used for the purposes set out in this Policy.

We may process Personal Data for several purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, safeguarding our rights and interests, supporting the maintenance and delivery of the Services, complying with applicable legal and regulatory requirements, and carrying out administrative and business operations necessary for the provision and use of the Services.
We also process Personal Data to better understand your preferences and requirements.

To access important tools that help protect your rights in relation to Personal Data:

To support the exercise of your rights, we have dedicated resources in place. You may contact us at any time to request access to your Personal Data. We can update or delete your information, restrict its use for specific or general purposes, and transfer it to you or to a third party. We will make every reasonable effort to fulfil your request.

Protect Your Personal Data:

While we cannot guarantee absolute security for your Personal Data, we are committed to using a range of measures and technologies to help keep your Personal Data protected.
Our Privacy and Security Policy provides full details.

1. The Scope?

This policy explains what types of Personal Data the Company collects about individuals, how that data is processed, when it may be shared with third parties, and the measures in place to keep it secure.
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 additional information that we hold or can reasonably access.
In this Policy, "processing" means any activity involving the use or collection of Personal Data. This includes organising, structuring, storing, and otherwise handling Personal Data.
Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect or seek information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we hold information relating to a child, we will delete it as soon as reasonably possible.

2. What Personal Data Do We Hold About You?

When you use our services and channels or visit our website, we collect Personal Data. In some cases, we ask you to provide your Personal Data directly. In other cases, we collect it by reviewing how our services or service channels are used, or by receiving your information from our third-party partners.

3. You are not required to provide the company with your personal information or explain the reasons for not doing so.

However, you are not required to provide us with any personal data. In some cases, if you choose not to provide certain personal data, we may be unable to deliver the Services or enable users to access the website.

4. What Personal Data may we collect? When you visit our website, we may collect the following personal information:

This includes details of your online activity records, traffic data such as your IP address, the date and time of access, the language used, software error logs, the browser type, and information about the device you used. The information collected does not constitute private information and cannot be used to identify you.
Personal Data We receive from you: any personal data that you choose to provide to Us when you connect through Us to a third-party online trading platform.
Personal information you provide directly to third-party platforms to enable trading: this information may include your full name, address, telephone number, and email address.

5. Legal basis and purposes for processing personal data

6. Disclosure of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, providers of IP address-related services, and user experience analytics providers.
You may also request that we transfer certain Personal Data relating to you to third-party trading platforms. In such cases, we will share the Personal Data you have provided to Us with those third-party trading platforms. Any use of your Personal Data by such platforms will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners where this is necessary to support, develop, and improve the products and services we provide to our customers.
Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to relevant regulatory, local, or other official authorities.
We may also share your Personal Data with prospective investors, purchasers, or lenders to the Company or to any other company within the group, where such disclosure is connected to the same transaction, including any transfer or sale of assets of the Company or any other group company, or as part of any merger, restructuring, consolidation, or insolvency process involving the Company or any other company within the group.

7. Cookies and third-party services

We may use third-party services, including advertising providers on our website and analytics companies. These providers may also use cookies and similar technologies.
Cookies are small text files stored on your device whenever you visit or access the website. They help collect information about your preferences and browsing activity so we can enhance your user experience, remember your settings, and tailor products and services that may be relevant to you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporary files downloaded to your device and remain active 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 make it easier for you to revisit the website.

Types of Cookies:

We may use them in line with their intended purpose:

ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. How long we retain your personal data

The Company will retain your Personal Data only for as long as needed to fulfil the purposes for which it is processed, as set out in this Policy, or for longer where permitted under applicable laws, regulations, internal policies, or binding requirements.
We will share your information with third-party trading platforms for a period of 12 months. Where you provide your consent, we will continue sharing your data for a further 12 months.
We review the Personal Data we hold on a regular basis to make sure it is no longer retained once it is no longer required.

9. Transfer of personal information to third countries or international organisations

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against its accidental or unlawful destruction, loss, or alteration.
While we take reasonable steps to maintain the security of your Personal Data, we cannot guarantee that such security will always be error-free. We are also not liable for any indirect, incidental, or consequential damages arising from the use of, or disclosure of, Personal Data, including, without limitation, any disclosure resulting from transmission errors, unauthorised access by third parties, or other circumstances beyond our reasonable control.
Where required by law or due to circumstances outside our control, we may need to disclose your Personal Data to third parties, such as competent public authorities. In such cases, we are unable to control the level of protection applied to your Personal Data by those third parties.
The transmission of Personal Data over the internet is not completely secure. The Company cannot guarantee the security of any Personal Data transmitted to Us online.

11. Links to Third-Party Websites

The website may include links to third-party websites and applications. These websites and applications are not under the Company's control or supervision. We are not responsible for how such websites or applications collect or process Personal Data. This Policy does not apply to any actions taken through those websites or applications.
If you visit any third-party website or application, we recommend reviewing its privacy policy before deciding to access or use it. We also advise you to consider carefully before sharing any Personal Data with them.

12. Changes to This Policy

Before visiting any third-party website or using any third-party app, we recommend that you review their privacy policies carefully and decide whether you wish to access or use their services. We also advise you to consider this before sharing any Personal Data with them.

13. Your rights regarding your personal information

You have the right to ask us to confirm whether we process Personal Data about you, to correct any inaccuracies, and to delete any Personal Data that we no longer need. You may also request that we limit certain types of processing of 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, you may send an email to the address below.
Access rights
The Company can confirm whether Personal Data relating to you is being processed. Where this is the case, you are entitled to access your 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 in electronic form.
The right to access Personal Data must not adversely affect the rights and freedoms of others. If fulfilling your request would prejudice the rights and freedoms of another person, the Company may refuse the request or limit the extent to which it can be fulfilled.
Right to rectification
The Company may correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right to erasure
This right applies in the following circumstances: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data concerning you where such processing is based on legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased in order to comply with a legal obligation binding on 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.
Processing restrictions
If you contest the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing has been restricted, Personal Data may only be stored unless you give your consent, or where it is necessary for the establishment, exercise, or defence of legal claims, for the protection of the rights of another natural person, or for reasons of important public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You are also entitled to request that your Personal Data be transferred directly by the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights and freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data concerning you where such processing is based on the legitimate interests pursued by the Company or by a third party. This includes profiling based on those legitimate interests. If we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or if processing is required for the establishment, exercise, or defence of legal claims, we may continue such processing.
In relation to direct marketing, you have the right at any time to object 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. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn.
You have the right to lodge a complaint with the relevant supervisory authority.
You may submit a complaint to a supervisory authority established to protect individuals’ rights in relation to the processing of Personal Data.
Applicable laws may limit your rights in relation to your Personal Data, as set out in this section 13.
We will provide the information requested in connection 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.
Unless otherwise permitted under section 13 or applicable law, the information you request in connection with your rights under section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also refuse to act on the request.
If we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to verify that person’s identity.