Privacy Policy

We are transparent about how we collect and process your personal information.

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods to keep you informed about Personal Data practices relevant to you.
Where specific details are required, we will provide them at the appropriate time.
If you have any questions or need clarification on any legally imposed limitations, we are happy to help. You can reach us by email at: info@rillstreamcapital.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for several purposes: to provide the website and connect you to third-party trading platforms (the "Services"); to improve the site; to protect our rights and interests; to maintain and deliver the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities that support the use of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights over your Personal Data, you have access to the following tools:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request.

Protect Your Personal Data:

While we cannot guarantee the complete security of your personal data, we are committed to employing a range of methods and techniques to protect it.
Our Privacy and Security Policy is complete.

1. The Scope?

This Policy describes the types of personal data the Company collects about natural persons, and how that data is processed, shared with third parties, and secured. This Policy applies to 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 information we hold or can reasonably access. For the purposes of this Policy, "processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage. Our services are intended for users aged 18 and above. We do not knowingly solicit or collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data belonging to a person under 18 has been collected, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our services and channels, or via information received from our third-party partners.

You are not required to share personal information with the company. However, choosing not to do so may prevent us from delivering our Services or granting you access to the website.

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 Do We Collect? When you visit our website, we collect the following personal data:

This includes information collected automatically when you use our platform: your online activity log, traffic data (including IP address, date and time of access), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily provide when connecting to a third-party online trading platform through Us.
Personal information provided 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 Personal Data We process your personal data on the following legal grounds: a) Performance of a contract — where processing is necessary to fulfil our obligations under a contract with you, or to take steps at your request before entering into one. b) Legal obligation — where processing is required to comply with a legal obligation to which we are subject. c) Legitimate interests — where processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests. d) Consent — where you have given clear consent for us to process your personal data for a specific purpose. The specific reasons we collect and process your personal data include: providing and managing our services, verifying your identity, communicating with you, processing transactions, maintaining the security of our platform, meeting applicable legal and regulatory requirements, and improving our services. Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Where providing personal data is a contractual or statutory requirement, failure to provide it may prevent us from delivering our services or granting you access to the website. We will inform you at the point of collection whether the provision of data is mandatory and the consequences of not providing it.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: Service Providers: We engage trusted third-party service providers to perform functions on our behalf, including payment processing, data analytics, customer support, and IT infrastructure. These providers are authorised to use your personal data only as necessary to deliver those services and are bound by confidentiality obligations. Business Transfers: If we undergo a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We will notify you of any such transfer and any material changes to how your personal data is handled. Legal and Regulatory Obligations: We may disclose your personal data to regulators, law enforcement agencies, or other authorities where required by law or where we have a good-faith belief that disclosure is necessary to comply with a legal obligation, protect our rights, or prevent fraud. Third-Party Integrations: Where you choose to connect third-party services or platforms to your account, your personal data may be shared with those third parties in accordance with your instructions. We are not responsible for how those third parties handle your data. All third parties with whom we share personal data are required to implement appropriate security measures and to process your data only for the purposes specified. We do not sell your personal data to third parties.

We may share your Personal Data with third-party service providers — including hosting and storage providers — as well as companies that help us analyse user experience. You may also request that we share specific Personal Data with third-party trading platforms of your choosing. In such cases, we will transfer the Personal Data you have provided to us directly to those platforms. Once shared, your Personal Data is subject to the privacy policies of the respective trading platforms. Your Personal Data may be shared with more than one trading platform. We may share Personal Data with related entities or business partners where this supports the development and improvement of our products and services. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities. We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within the group — in connection with a transaction such as a transfer or sale of assets, merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. These may collect data about your browsing activity and use it to deliver personalised content, ads, or functionality. Third-party providers operate under their own privacy policies, which we encourage you to review. By continuing to use our website, you consent to the use of cookies in accordance with our Cookie Policy. You can manage or withdraw your cookie consent at any time through your browser settings or our cookie preference centre. Please note that disabling certain cookies may affect the availability or performance of some website features.

We may work with third-party service providers, including advertising networks and analytics companies, to support our website. These providers may also use cookies or similar tracking technologies.
Cookies are small text files placed on your device when you visit our website. They collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and personalise the products and services shown to you. Cookies are also used for statistical and analytics purposes.
We use two types of cookies. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and allow the website to recognise you as a returning user, making it easier to resume your previous activity.

Types of Cookies:

We may use them based on their purpose.

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We 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.
Your information will be shared with third-party trading platforms for 12 months. Where you provide consent, this sharing will continue for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required and act accordingly.

9. Transfers of Personal Information to a Third-Party Country or International Organisation We may transfer your personal information to recipients located in countries outside your own, including to international organisations. Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal information in accordance with applicable data protection requirements. These safeguards may include standard contractual clauses, adequacy decisions, or other legally recognised transfer mechanisms. By using our services, you acknowledge that your personal information may be transferred, stored, and processed in a country other than where you reside.

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration, or disclosure. Access to your personal data is restricted to employees, agents, contractors, and third parties who have a legitimate business need to process it. They are bound by confidentiality obligations and will only process your personal data on our instructions. We have procedures in place to handle any suspected personal data breach. Where legally required, we will notify you and the relevant regulatory authority of a breach. No data transmission over the internet is completely secure. While we take all reasonable steps to protect your personal data, we cannot guarantee its absolute security. You are responsible for keeping any access credentials confidential and for not sharing them with anyone.

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third-party access, or other causes beyond our control. Where legal or other obligations require it, we may be required to disclose Personal Data to third parties, including public authorities. We have no control over how such third parties manage the security of your Personal Data in those circumstances. Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us through the internet.

11. Links to Third-Party Websites

Our website contains links to third-party websites and applications. These sites and apps are not operated or supervised by the Company, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through third-party sites or apps.
Before accessing or using any linked third-party website or app, we recommend reading their privacy policy carefully. We also advise caution when sharing any Personal Data with them.

12. Modifications to this Policy We may update this Policy from time to time. When we do, we will revise the effective date at the top of this page. If changes are material, we will notify you through the platform or by other appropriate means. Continued use of our services after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how we protect your information.

Before visiting any third-party website or app, read its privacy policy carefully. Only share personal data with third parties once you have reviewed and are comfortable with how they handle it.

13. Your Rights Regarding Your Personal Information You have the following rights in relation to your personal data: Right of Access — You may request a copy of the personal data we hold about you and details of how we use it. Right to Rectification — If any personal data we hold is inaccurate or incomplete, you have the right to request that we correct it. Right to Erasure — You may request that we delete your personal data where there is no legitimate reason for us to continue processing it. Right to Restriction — You have the right to ask us to suspend processing of your personal data in certain circumstances, such as where you contest its accuracy. Right to Data Portability — Where applicable, you may request that we transfer your personal data to you or a third party in a structured, commonly used, machine-readable format. Right to Object — You may object to the processing of your personal data where we rely on a legitimate interest as the legal basis for that processing. Right to Withdraw Consent — Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within the timeframe required under applicable law. Please note that certain rights are not absolute and may be subject to limitations depending on the circumstances.

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 request that we restrict the types or scope of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
Where Personal Data about you is being processed, you have the right to access that data. The Company will provide an electronic copy of the Personal Data currently being processed. A reasonable fee may be charged for additional copies. If your request conflicts with the rights and freedoms of another individual, the Company may refuse or limit its response accordingly.
Right to rectification
You have the right to require the Company to correct inaccurate Personal Data. Where Personal Data about you is incomplete, you may request that it be rectified, taking into account the purpose for which it is being processed.
Right to Erasure
You may request erasure of your Personal Data where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) erasure is required to comply with a legal obligation.
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.
Processing restrictions
If you question the accuracy of your Personal Data, you may request that the Company restrict its processing. Where restriction is requested, Personal Data may only be processed with your consent, to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.
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 party, you have the right to receive the Personal Data you have provided to the Company in a structured format. You may also request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure, and does not infringe the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data about you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where you object, the Company will cease processing unless it can demonstrate compelling legitimate grounds that override your rights, interests, and freedoms, or where processing is necessary for the establishment, exercise, or defense of legal claims.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
Right to withdraw consent
You may withdraw your consent to the 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 the relevant supervisory authority. This is the authority established by a Member State to oversee the protection of individuals' rights in relation to the processing of Personal Data within the European Union.
Laws of the European Union and its Member States may limit the rights described in this section.
The Company will respond to requests made under this section within one month of receipt. Where necessary, this period may be extended by up to two additional months, depending on the complexity and volume of requests. You will be notified of any such extension, along with the reasons for it, within one month of your original request.
Unless otherwise provided under this section, information provided in response to your requests will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly where they are repetitive, the Company may charge a reasonable administrative fee or decline to act.
Where there is reasonable doubt regarding the identity of the person making a request, the Company may request additional information to verify that identity.