TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We are committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Ruvenmerit (the "Website").
We want you to be well-informed about how your Personal Data is used and processed. We use a range of methods to keep you up to date with relevant information, and where specific details are needed, we'll provide them at the appropriate time. If you have any questions about legal limitations that apply, we're happy to help.
1. The Scope
This policy explains what Personal Data the Company collects about individuals, and how that data 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 identified directly, or through a combination of 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 available to anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we 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
2.1 When you access our services, channels, or website, we collect personal data. In certain instances, we may request specific personal data from you.
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 granting you access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and traffic data, such as:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
The information we collect is not personal information 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, in accordance with the applicable legal basis.
5.2 The Company may only process Personal Data about you where a valid legal basis exists. The legal grounds on which the Company may rely to process your Personal Data are:
- By submitting personal data through this website, you consent to its processing for one or more specified purposes, including transferring that data to a third-party trading platform.
- We, or a relevant third party, may process your data to pursue legitimate interests — such as improving our Services or defending legal claims.
- Processing must meet an obligation of law.
For more information about the processing we carry out to protect our legitimate interests, please contact us by email.
5.4 The following outlines the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
If you request it, we may collect and forward your personal data to third-party companies to facilitate access to digital trading.
You have consented to the processing of your personal data for one or more purposes.
2. To respond to your requests, questions, or concerns
We use your personal data to address any questions you have about our Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
Personal data is processed to meet applicable legal, administrative, and judicial obligations.
To ensure compliance with legal obligations, processing is required.
4. To Improve Our Services
We may use personal data to improve Our Services, including through crash reports and malfunction data collected in connection with the Services.
Processing this data is necessary to support the legitimate interests of the Company or a relevant third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
6. To perform and manage activities required to deliver Our Services
This includes back-office operations, business development, strategic decision-making, and oversight functions.
Processing is required to support the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas of our operations.
Processing is necessary to support the legitimate interests of the Company or a third party.
8. To protect our assets, rights and interests, and those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant conditions, terms or policies.
Processing data in the legitimate interests of the Company or a third party.
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 your Personal Data with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to those platforms. Your Personal Data shared in this way is governed by the privacy policies of the respective third parties. 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 support the enhancement and improvement of 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 or buyers, or with lenders to the Company or any other company within the group, in connection with a transaction such as an asset transfer or sale, 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 engage third-party services, such as advertisers and analytics providers, on our website. These third parties may also use cookies or similar tracking technologies.
7.2 Cookies are small text files placed on your device each time 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 analytics purposes.
7.3 Some cookies used on this website are session cookies. These are temporarily downloaded to your device and 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 session when you visit again.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and allow you to use site features and return to previously visited pages.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify you're logged in. They're deleted automatically when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies recognise you each time you visit our site and save your preferences.
Additional Information
These cookies persist until their expiry date and remain stored even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data and analyse our website's performance, helping us improve your experience over time.
Additional Information
Cookies store anonymous data that is not associated with any identifiable individual. Some cookies are removed when you close your browser, while others remain valid indefinitely.
7.4 If cookies are blocked or removed, you'll need to adjust your browser settings. The links below walk you through the process for some of the most common browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some or all of the Website's features may not function as expected if this occurs.
Online Tracking Notice: This service does not currently respond to 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 any longer period permitted by applicable laws, regulations, or orders.
8.2 We will share your information with third-party trading platforms for 12 months. If you agree, 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
Your personal information may be transferred to other countries or to international organisations. We take all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.
These protections and safeguards apply to all residents of the EEA (European Economic Area):
- Transfers to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- This transfer is made under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
- This transfer was made in accordance with standard contractual clauses adopted by the European Commission under Article 46(2)(c) of the GDPR.
9.3 We can provide details about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@ruvenmerit.com
10. Security of Personal Data
10.1 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 free from error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including where such disclosure results from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.
10.3 In some circumstances, we may be legally or otherwise obligated 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 protect 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 online.
11. Hyperlinks to Third Party Websites
11.1 This website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how these sites or apps collect or process personal data. This Policy does not apply to any actions taken through such sites or apps.
11.2 When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. We also advise caution when sharing any personal data with them.
12. Modifications to This Policy
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 significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.
Unless otherwise specified, 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 scope or types of processing applied to your personal data.
If you are an EEA resident, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, contact us at 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 the Personal Data currently being processed and may charge a reasonable fee for additional copies. This right to access must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another person, the Company may refuse to comply or limit the extent to which it fulfils the request.
13.4 Right to rectification We may correct any inaccurate Personal Data we hold about you. You may also 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, on grounds relating to your specific situation, to processing of your Personal Data where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data have been 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 an obligation imposed 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 ask the Company to restrict its processing. Where 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 there is a significant 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 format and to request that it 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 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 prior to that withdrawal. You have the right to lodge a complaint with a relevant supervisory authority. Within the European Union, you may lodge a complaint with a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data. Please note that the laws of the European Union and its member states 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 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 section 13 of the law, information provided in response to a rights request will be made available at no cost. Where a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, or we may decline to act.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide sufficient information to verify their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Ruvenmerit 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@ruvenmerit.com