Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects on natural individuals, and how that data is processed, shared with third parties, and secured.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly by reference to additional information we hold or can access.

1.3 Under the Policy, "processing" means any operation that uses or collects Personal Data, including its management, organisation, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18, nor do we knowingly permit such individuals to use our services. If we discover that we hold information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access our service and channels or visit our website. In certain cases, we may request your Personal Data directly.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. However, withholding such information may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.2 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 you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly 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 of Personal Data

5.1 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.

5.3 Contact us by email for more details on the processing required to protect our legitimate interests.

5.4 We may use the information you provide for the following reasons and legal grounds:

6. Transfer of Personal Data to Third Party

6.1 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 analysis of user experiences.

6.2 You can also request that we share specific Personal Data about you with third-party trading platforms. In these instances, we will provide the Personal Data you have given to Us to such third-party trading platforms, where its use is governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This provides the Company with the resources needed to enhance and improve the products and services it offers its customers.

6.4 Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, where such a 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 of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or similar technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services you may find useful. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily stored on your device and remain only until you close your browser. Others are persistent cookies, which stay on your device for a period after you close your browser. These help the Website recognise you as a returning user and make it easier to revisit the site.

7.5 If this occurs, please note that some or all of the Website's functions and features may not work as expected.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

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

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to a third country or to international organizations. Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 Upon request, the Company can provide details of the security measures used to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@trove-vestmark.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed through transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Where legal or other obligations beyond our control apply, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to Us over the internet.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's control. We are not responsible for the collection or processing of Personal Data by them. This Policy does not apply to actions taken through such sites or applications.

11.2 When you visit any third-party website or app, we recommend reviewing their privacy policies before deciding to access or use them. We also suggest exercising care before providing any Personal Data to them.

12. Modifications to This Policy

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

12.2 We will also notify you of any significant changes to this Policy through methods we consider appropriate, and we will publish an announcement on our website.

12.3 Unless otherwise specified, any amendments take effect once the revised Policy is published.

13. Your Rights

13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the scope and types of processing applied to your Personal Data.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the Personal Data you provide. To exercise them, please send an email to the address below.

13.3 Right of access You may ask the Company to confirm whether your Personal Data is being processed. If it is, you have the right 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 any additional copies. Where you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You have the right to request rectification of incomplete Personal Data concerning you, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to comply with the company's legal obligation. This right does not apply where the processing is necessary (a) to fulfil a legal obligation that requires processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.

13.6 Restriction of processing If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request that Personal Data be restricted, it may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is automated and based on your consent or a contract to which you are a party, you have the right to access the Personal Data you have provided to the Company. 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 rights under the right to erasure. This right 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 any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we have established compelling legitimate grounds for processing, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests override those grounds, or unless the processing is necessary for the exercise, establishment, or defense of legal rights. You also have the right to object at any time to the processing of Personal Data concerning you for direct marketing purposes.

13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals regarding 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 concerning you, as set out in this section 13.

13.10 We will provide the information you are entitled to under section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and number of requests. We will notify you of any extension, along with the reasons, within one month of receiving your request.

13.11 Unless section 13 of the law provides otherwise, the information you request under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or acting on the request. We may also decline to act.

13.12 If we have reasonable doubts about the identity of the person submitting your request, we may require that person to provide reasonable means of verifying their identity.