Privacy Policy

1. The Scope

This policy sets out 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 In this Policy, "processing" refers to any activity involving the use or collection of Personal Data, including its organisation, structuring, and storage.

Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we knowingly permit them to use our services. If we become aware that any 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. We may also request personal data from you in certain circumstances.

2.2 In other cases, we collect your personal data by analysing how our Services and service channels are used, or by receiving your information from 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 restrict your access to the website.

4. What Personal Data We Collect

The information collected is not personal data and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you choose to provide to us when connecting to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions: this includes 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 set out in this section, in accordance with the applicable legal basis.

For more information on the processing carried out to safeguard legitimate interests, please contact us by email.

5.4 The following sets out the purposes 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 services.

6.2 You may also request that we share specific personal data about you with third-party trading platforms. Where you make such a request, we will share the relevant personal data you have provided to us with those platforms. Your personal data shared in this way will be subject to the privacy policies of those third-party trading platforms. Please note that your personal data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with related entities or business partners to enhance and improve the products and services provided to customers.

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, buyers, or lenders to the Company or any other group company in connection with a transaction — including the transfer or sale of Company assets — or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party service providers, such as advertisers and analytics companies, who may also use cookies or similar tracking technologies on our website.

7.2 Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytical purposes.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device after your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and help you resume your visit seamlessly.

Please note that some or all of the Website's functions and features may not work as expected if this occurs.

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

8. Retention of 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 permitted by applicable law, regulation, or order.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to this, we will continue sharing your data for a further 12 months.

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

9.1 Your personal data may be transferred to other countries or to international organisations. The Company takes all necessary steps to protect the personal data you provide and to ensure that individuals retain the right to exercise effective legal recourse.

9.3 The Company can provide details of the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@bastionyielmere.com

10. Security of Personal Data

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

We cannot guarantee that your Personal Data will be kept secure at all times or that errors will never occur. We are not liable for any indirect, 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 reasonable control.

10.3 Where we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or secure your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot ensure the security of any personal data you send to us via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These are not under the Company's supervision, and we are not responsible for how such sites or applications collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.

When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using them. You should also take care when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.

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

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

13. Your Rights

You have the right to 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 data.

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

13.3 Access rights You have the right to verify whether the Company is processing Personal Data about you and, if so, to access that data. The Company will provide an electronic copy of any Personal Data currently being processed and may charge a reasonable fee for additional copies. Access requests will be fulfilled electronically unless otherwise agreed. This right must not conflict with the rights and freedoms of others. Where fulfilling a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to rectification We may correct inaccurate Personal Data held about you. You have the right to request that incomplete Personal Data be rectified, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request erasure 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 there is no other legal basis for processing; (c) you object to processing of your Personal Data based on legitimate interests pursued by Us or a third party, where no overriding legitimate grounds exist; (e) the Personal Data are unlawfully processed; or (f) erasure is required 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 under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where 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 where there is a substantial public interest reason 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 in a structured, commonly used format and to request that it be transferred directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue to process your Personal Data despite your objection. Concerning direct marketing, you have the right to object at any time to the processing of Personal Data concerning you for that purpose.

13.9 Right to withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent prior to that withdrawal. You have the right to lodge a complaint with your relevant supervisory authority. This includes any supervisory authority established by a European Union member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. Please note that EU and member state law may limit the rights described in this section 13.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to the provisions of section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — in particular where requests are repetitive — 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 on the request.

13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask them to provide suitable means of verification.