Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, including how it is processed, shared with third parties, and secured.

This Policy covers information relating to an identified or identifiable natural person. A person is considered identifiable if they can be directly identified, or identified 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 persons younger than 18, nor do we knowingly 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 ask you to provide personal data directly.

In some cases, we collect your personal data by analysing how you use our Services or service channels, 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is non-personal 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 with a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade 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 described in this section, under the applicable legal basis.

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

5.4 Below is a list of 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 processors, and user experience analytics services.

6.2 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 submitted to us directly to those platforms. Your Personal Data may be shared with one or more third-party trading platforms, and its use will be governed by their respective privacy policies.

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 competent authorities.

We may share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including the transfer or sale of company assets, or any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity 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 — that 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 collect information about your preferences and browsing habits 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.

Some cookies used on this Website are session cookies — temporary files downloaded to your device that expire 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 restore your previous session.

7.5 Please note that disabling cookies may cause some or all Website features to stop working as expected.

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

8. Retention of Personal Data

The Company 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 extend this 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 shared with international organizations. The Company takes all necessary steps to protect the personal data you provide and to ensure you can effectively assert your rights and access 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, contact us at: support@pledgewright.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 modification.

We cannot guarantee that your Personal Data will be kept secure without error at all times. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including disclosure caused by transmission errors, unauthorised third-party access, or other circumstances beyond our reasonable control.

10.3 Where required by 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 protect your Personal Data.

10.4 Transmitting personal data over the internet carries inherent security risks. The Company cannot guarantee the security of any personal data you send to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These sites and applications are not under the Company's supervision, 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 websites or apps, we recommend reading their privacy policies carefully. Exercise caution when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. Any changes will be reflected in the updated Policy posted 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 otherwise stated, any amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You have the right to request verification of the accuracy of your Personal Data we collect, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the scope of processing applied to your personal information.

If you are a resident of the EEA, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, send a written request to 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 to access must not infringe on the rights and freedoms of others. Where 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 The Company may correct any inaccurate Personal Data it holds about you. You have the right to request that incomplete Personal Data relating to you be rectified, having regard to the purpose for which it is processed.

13.5 Right to Erasure You may request the 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, on grounds specific to your situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure 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 restrict its processing. Once a restriction is in place, 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 a matter of significant public interest within the European Union or a Member State applies.

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. You may also request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not adversely affect the rights or freedoms of others.

13.8 Right to challenge You have the right to 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. This right is not limited to profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing your Personal Data 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 do so. Concerning direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to Refuse Consent You may withdraw your consent for Us to process your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with the relevant supervisory authority. This includes any 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. Please note that applicable European Union and Member State laws may limit your rights in relation to your Personal Data, as set out in this section 13.

We will respond to requests made under Section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity or volume of requests received. You will be notified of any extension, along with the reasons for it, within one month of your original request.

Subject to 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 — particularly where requests are repeated — 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 such requests.

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