Privacy Policy

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 directly identified, or identified through a combination of additional 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 aged 18 and above. We do not knowingly collect information from anyone under 18, nor do we permit minors to use our services. If we become aware that we hold information relating to a person under 18, we will delete it promptly.

2. What Personal Data Do We Have on You

When you access our services, channels, or website, we collect personal data. In certain instances, we may also request specific personal data from you.

2.2 We also collect your personal data by analysing how our Services and service channels are used, or by receiving your information from our 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 restrict your access to the website.

4. What Personal Data We Collect

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 voluntarily provide to us when you connect 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.

For details on how we process data to protect 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:

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, as well as companies that analyse user experience and IP address information.

6.2 You may also request that we share specific personal data about you with third-party trading platforms. Where you make such a request, we will transfer the relevant personal data to those platforms accordingly. Your personal data shared in this way will be governed by each platform's own privacy policy. Please note that your personal data may be shared with more than one third-party 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.

Where necessary to protect the rights of third parties or their assets, the Company may disclose Personal Data to regulatory, local, or other competent 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 relevant transaction — including the transfer or sale of company assets — or as part of a merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third-party services — such as advertisers and analytics providers — that operate on our website. These third parties may use cookies or similar tracking technologies independently.

7.2 Cookies are small text files placed on your device when 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 statistics and analytics purposes.

7.3 Some cookies used on this Website are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the Website recognise you as a returning user and allow you to resume access seamlessly.

Please note that disabling certain features may cause some or all Website functions to not work as expected.

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

8. Retention of Personal Data

The Company will retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

We periodically review the Personal Data we hold to determine whether it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries or shared with international organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the right to assert your rights and access effective legal recourse.

9.3 The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@accrudonage.com

10. Security of Personal Data

We have implemented appropriate organizational 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 and without error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data — including, but not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our reasonable control.

10.3 In some circumstances, we may be legally required to share your Personal Data with third parties, including public authorities. Where this applies, we have no control over how those third parties handle or secure 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 third-party sites or apps collect or process Personal Data. This Policy does not apply to any actions taken through such sites or applications.

11.2 When visiting any third-party websites or apps, read their privacy policies before accessing or using their services. Exercise caution when sharing any personal data with them.

12. Modifications to This Policy

This Policy may be updated at any time. When changes are made, the updated Policy will be posted on our website.

12.2 When we make significant changes 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 verification of the accuracy of your Personal Data, to correct any inaccuracies, and to request deletion of any Personal Data we no longer require. You may also restrict the scope or type of processing applied to your personal information.

If you are a resident of the EEA, please refer to this page for information on your rights regarding your Personal Data. To exercise any of these rights, send an email to the address below.

13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. If Personal Data is being processed, you have the right to access it. The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its compliance with that request.

13.4 Right to rectification The Company may rectify any inaccurate Personal Data it holds. You have the right to request the correction of incomplete Personal Data relating to you, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request the 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 to the processing of your Personal Data based on legitimate interests pursued by us or a third party, and no overriding legitimate grounds exist; (e) the Personal Data are unlawfully processed; or (f) erasure is required to fulfil 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 law or Member State law; or (b) to establish, exercise, or defend legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing. Where such a restriction is requested, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another natural person, or where there is a 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 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, commonly used 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. The right to data portability must not adversely affect the rights or freedoms of others.

13.8 Right to Object You have the right at any time to object 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 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 do so. Regarding 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 for Us processing 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. Within the European Union, you may submit a complaint to 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 your request, in line with the rights set out in 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, along with the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, any information you request under your section 13 rights will be provided at no cost. However, if a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of fulfilling it. We may also decline to act on such requests.

13.12 If we have doubts about the identity of the person submitting your request, we may ask them to provide reasonable verification of their identity.