Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural 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 management, organization, and storage.

Our services are intended for general audiences. We do not permit anyone under the age of 18 to use our services, and we do not knowingly collect information from minors. If we become aware that we hold data belonging to a person under 18, 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 analyzing 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 granting you access to the website.

4. What Personal Data We Collect

The information collected is non-personal 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 to a third-party online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading 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 more information about the processing carried out to protect legitimate interests, contact us by email.

5.4 The following sets out 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 companies that provide services on our behalf, including hosting and storage providers, IP address data, and user experience analytics.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data to those platforms as requested. Your Personal Data will then be governed by their respective privacy policies. Note that 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 enhance and improve 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 relevant transaction — including any transfer or sale of Company assets, 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 work with third-party service providers — such as advertisers and analytics companies — that operate 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 most relevant to you. Cookies are also used for statistical and analytics purposes.

7.3 We use two types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognise you as a returning user, allowing the website to restore your previous session.

Please note that disabling certain Website functions may cause some or all features to behave unexpectedly.

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

8. Retention of Personal Data

We retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for any longer period permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 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 to 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@vireowertholm.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 modification.

We cannot guarantee that your Personal Data will be kept secure at all times and free from error. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.

10.3 In certain circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, such as public authorities. In those situations, we have no control over how those third parties safeguard your Personal Data.

10.4 Transmitting Personal Data over the internet carries inherent security risks. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

Before accessing any third-party website or app, review their privacy policy. Exercise caution when sharing personal data with third parties.

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 may request that we verify the accuracy of the Personal Data we hold 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 reside in the EEA, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. Where applicable, you may 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 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 inaccurate Personal Data at any time. You have the right to request that incomplete Personal Data relating to you be corrected, taking into account 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 no legal basis for processing exists; (c) you object to the processing of your Personal Data based on a reason specific to your situation, where that processing relies on legitimate interests pursued by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required to comply with a legal obligation applicable to 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 rights.

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 individual, 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 your Personal Data in a structured, commonly used format. You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising your right to data portability 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 challenge You have the right at any time to object to any processing of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This right is not limited to profiling based on those interests. If we demonstrate compelling legitimate grounds for the processing, we may continue unless you establish that your rights, freedoms, or interests override those grounds, or that the processing affects the exercise, establishment, or defense of legal rights. Regarding direct marketing, you have the right at any time to object to the processing of your Personal Data.

13.9 Right to Refuse Consent You may withdraw your consent for Us to process your Personal Data 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 relevant 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 the rights described 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, 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 free of charge. If a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

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