Privacy Policy

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects from 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 by combining additional information we hold or can access.

1.3 Under this Policy, "processing" means any operation involving the use or collection of Personal Data, including its management, structuring, 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 anyone under 18, nor do we knowingly permit such persons to use our services. If we learn 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 When you access the service and channels or visit our website, we collect Personal Data. 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 offering the Services or prevent you from accessing the website.

4. What Personal Data We Collect

4.2 The information we collect 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 set out in this section, in accordance with the applicable legal basis.

5.3 Contact us by email for more details about the processing necessary to protect legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following 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 ask us to share specific Personal Data about you with third-party trading platforms. In these instances, we will provide the Personal Data you give us to those third-party trading platforms. Their use of your Personal Data is governed by their own 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 offered to its customers.

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

6.5 We may also share Personal Data about you with potential investors or buyers, with lenders to the Company or any other company within the group, where such a transaction occurs (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 other 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 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 downloaded to your device and last only until you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the Website recognise you as a returning user and make it easier to return to the site.

7.5 However, please be aware that some or all of the Website's functions and features may not work as expected if this occurs.

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 consent to this, 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 international organizations. The 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 The Company can provide details of the security measures it applies to protect your Personal Data transferred to third-party countries or international organisations. Email: support@noble-velmark.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational 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, nor can we be held accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to 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 require it, we may need to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security those third parties apply to your Personal Data.

10.4 No method of transmitting Personal Data over the internet is completely secure. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to Third Party Websites

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

11.2 When you visit any third-party website or app, we recommend reading their privacy policy before deciding to access or use it. We also advise caution before providing any Personal Data to them.

12. Modifications to This Policy

12.1 We may update this Policy at any time. Any changes will be communicated by posting the updated Policy on our website.

12.2 We will also take appropriate steps to notify you of any significant changes to this Policy and will publish an announcement on our website.

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

13. Your Rights

13.1 You have the right to ask us to confirm 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 information.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the Personal Data you provide. To exercise your rights, please send an email to the address below.

13.3 Access rights The Company can confirm whether your Personal Data is being processed. If it is, you may access that 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. If 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. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with it or limit the extent to which it is fulfilled.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, 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 legal basis for processing; (c) you object at any time, on grounds specific to your situation, to the processing of Personal Data about yourself 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 a legal obligation of the company. This right does not apply where 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 rights.

13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, the Personal Data may only be retained with your consent, or to establish, exercise or defend legal claims, or to protect the rights of another natural person, or for reasons of substantial public interest 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 on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company. You may also 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. This right must not adversely affect the rights and 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. This includes profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing, we may continue to do so unless you can show that your rights, freedoms, or interests prevail, or that the processing is necessary for the exercise, establishment, or defence of legal rights. As regards direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

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 on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may submit a complaint 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 regarding Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information requested under your rights in Section 13 of this agreement within one month of receiving your request. Depending on the nature and number of requests, this period may be extended by up to two further months. We will inform you of any such extension, and the reasons for it, within one month of receiving your request.

13.11 Provided it is not contrary to section 13 of the law, the information you request under your section 13 rights will be provided free of charge. Where a request is unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the action requested. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable proof of identity.