Privacy Policy
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the website https://truethriftavence.com (the True Thriftavence ).
The following principles will be upheld:
We want you to be well-informed when making decisions about the use and processing of your Personal Data. We use a variety of methods to ensure you receive the relevant information you need. Where we consider that specific details are required, we will provide them to you at the appropriate time. We are always happy to address any questions you may have regarding any limitations imposed by law.
1. The Scope?
This policy describes the types of Personal Data that True Thriftavence collects about natural individuals, and how it processes, shares with third parties, and secures that data.
This Policy relates to information concerning an identified or identifiable natural person. An identifiable natural person is defined as someone who can be directly identified, or identified through a combination of additional information we hold or are able to access.
The Policy defines "processing" as any operation that involves the use or collection of Personal Data, including its management, organisation, and storage.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18 years of age, nor do we knowingly permit such persons to use our services. Should we become aware that we hold information relating to a child, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels, or visit our website, we collect Personal Data. In some instances, we may ask you to provide your Personal Data directly. In others, we gather it by analysing how our Services and service channels are used, or by receiving information about you from our third-party partners.
3. There is no requirement to disclose personal information to the company, nor any consequences for declining to do so.
You are not obliged to provide us with any personal data. However, in certain circumstances, choosing not to do so may limit our ability to deliver the Services or restrict your access to the website.
4. What types of Personal Data do We collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity log, data about your traffic (including your IP address, date of access, time of access, and date of access), the language you used, software crash logs, the type of browser used, and information regarding the device you used. The information collected is not personal information and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us of your own choosing when you connect with an online trading platform of a third party through Us.
Personal information you provide directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.
5. The Legal Basis and Reasons for Processing Personal Data
Your personal data is processed by the Company for the purposes described in this section, and in accordance with the applicable legal basis.
Without a valid legal basis, the Company is unable to use your personal data. The legal grounds upon which the Company may process personal data relating to you are as follows:
- You have given your consent to the processing of your personal data for one or more purposes. This applies when you submit personal information via the Website so that we may pass it on to a third-party trading platform.
- The Company, or a third party, may need to process your data in order to pursue legitimate interests — for example, to improve Our Services or to defend legal claims.
- Processing is required to comply with a legal obligation.
Contact us via email for further details on the processing required to protect legitimate interests.
Below is a list of the reasons and legal bases upon which we may use the information you provide us. Personal Data.
Scope, Legal Basis
1. To share your personal information with third parties at your request, in order to facilitate access to digital trading. If requested, we may ask for your Personal Data in order to pass it on to third-party companies.
You have given your consent to the processing of your personal data for one or more purposes.
2. To address your requests, questions, or concerns. Personal Data is required in order to respond to any queries you may have regarding the Services.
Processing is necessary to support the legitimate interests of the Company or those of a relevant third party.
3. Personal data is processed to fulfil legal, administrative, and judicial obligations, as required by applicable law.
To meet our legal obligations, some processing of your data is necessary.
4. Personal data may be used by us to improve Our Services. This includes, amongst other things, crash reports and malfunction data collected in relation to the Services.
Processing is necessary to pursue the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. To carry out and manage activities that align with the requirements of Our Services. This includes back-office functions, business development, strategic decision-making, oversight mechanisms, and related operational activities.
Processing is necessary for the legitimate interests of the Company or those of a third party.
7. To carry out analysis, including statistical analysis, we employ a range of analytical techniques — including statistical methods — to inform decisions on various matters.
Processing is necessary for the legitimate interests of the Company or those of a third party.
8.
To protect our assets, rights, and interests, as well as those of third parties, we have taken steps to establish and defend legal claims.
Personal Data may be processed by us to safeguard 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 is necessary for the legitimate interests of the Company or those of a third party.
6. Transfer of Personal Data to Third Parties
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 user experience analytics.
You may also request that we share specific Personal Data relating to you with third-party trading platforms. In such instances, we will provide the Personal Data you have supplied to us directly to those third-party trading platforms. The use of your Personal Data will be subject to their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources required to enhance and improve the products and services it offers to its customers.
Where it is necessary to protect the rights or assets of third parties, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with prospective investors or purchasers, or with lenders to the Company or any other company within the group, in the event that 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 insolvency proceedings involving the Company or any other business within the group.
7. Cookies and Third-Party Services
Third-party services, such as advertising providers or analytics companies, may be used in connection with our website. These companies may also make use of cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They are used to gather information about your preferences and browsing habits in order to improve the user experience, remember your preferences, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for the duration of your browsing session, expiring once you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They are used to help the website recognise you as a returning user and enable you to pick up where you left off.
Types of Cookies:
They may be used by us according to their purpose:
1. Cookies are strictly necessary
These cookies are necessary for accessing the features you have requested and for navigating our website. They are used to deliver the information, products, and services you have asked us to provide.
They are required for your device to download and stream data, allowing you to browse the website, make use of its features, and return to pages you have previously visited.
Cookies collect personal data, such as your username and last login date, to confirm that you are signed in to the site. They are deleted once you close your web browser (session cookies).
2. Functionality Cookies
Cookies enable us to recognise you each time you visit our site, as well as save your settings and preferences.
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
3. Cookies for performance
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to carry out analysis on our website.
Cookies store anonymous data that is not associated with any identified or identifiable individual. Some cookies are removed when you close your browser, whilst others remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you will need to adjust your browser settings. Below are links to guide you through the process for some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please be aware that if this occurs, some or all of the Website's functions and features may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. The retention of Your personal data
The Company will retain your Personal Data for as long as is necessary to fulfil the purpose for which it was collected, as described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer required.
9. Transfers of Personal Information to a Third-Party Country or International Organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — one other than your country of residence — or to international organisations or jurisdictions). The Company takes all necessary steps to safeguard the personal data you provide, and to ensure that data subjects are able to exercise their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide further information about the security measures it employs to protect your Personal Data when transferred to third-party countries or international organisations. Please send an email to info@truethriftavence.com
10. Security of Personal Data
We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or modification.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or any other cause beyond our reasonable control.
In circumstances where legal or other obligations beyond our control require it, we may be required to disclose Personal Data about you to third parties, such as public authorities. We are unable to control the level of security applied to your Personal Data by such third parties in these situations.
Personal Data cannot be transmitted over the internet in a wholly secure manner. The Company cannot guarantee the security of any Personal Data you transmit to us via the internet.
11. Links to Third-Party Websites
Links to third-party sites and applications may be provided on this website. These sites and applications are not under the supervision of the Company. We accept no responsibility for the collection or processing of Personal Data by such websites or applications, and this Policy does not apply to any actions taken through them.
When visiting any third-party websites or applications, we strongly recommend that you read their privacy policies before choosing to access or use them. We also advise that you exercise caution when sharing any Personal Data with them.
12. Amendments to this Policy
When visiting any third-party websites or apps, we recommend reading their privacy policies before choosing to access or use their services. We also advise caution when sharing any Personal Data with them.
13. Your rights regarding your personal information
You have the right to request that we verify the accuracy of the Personal Data we hold about you, to correct any inaccuracies, and to delete any Personal Data that we are not required to retain. You may also restrict the scope and types 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 information you provide in connection with your Personal Data. You may exercise any of these rights by sending an email to the address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. Where this is the case, you are entitled to access your 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. Data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request is detrimental to the rights or freedoms of another person, the Company may decline to comply with the request or limit the extent to which it can fulfil it.
Right to rectification
The Company is obliged to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data held about you be corrected, taking into account the purposes for which it is processed.
Right to Erasure
The following grounds apply: (a) Personal Data are no longer necessary for the purposes 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 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) Personal Data are unlawfully processed; or (f) Personal Data must be erased 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 rights.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where Personal Data processing is restricted, Personal Data may only be retained with your consent, or in order to establish, exercise, or defend legal rights, or 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 a party, you have the right to receive the Personal Data you have provided to the Company in a structured format.
You are entitled to 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 right to erasure. The right to data portability does not adversely affect the rights or freedoms of others.
Right to object
You have the right at any time to object to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those legitimate interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is not necessary for the establishment, exercise, or defence of legal rights, we will cease such processing.
Regarding direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of Personal Data about you at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal.
You are entitled to lodge a complaint with a supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to uphold the fundamental rights of individuals in relation to 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.
We will provide you with the information requested in accordance with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the complexity and volume of requests. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.
Subject to the provisions of section 13, information provided in response to a request made pursuant to your rights under section 13 will be provided free of charge. Where a request is manifestly unfounded or excessive, in particular where requests are repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the action requested, or we may decline to act.
Where we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to verify their identity.