Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about individuals, 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 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 and are not available to anyone under the age of 18. We do not knowingly collect information from, or permit access to, persons under 18. If we become aware that such information has been collected, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect personal data. We may also request personal data from you in certain circumstances.

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

4. What Personal Data We Collect

The information collected is not personal information and cannot be used to identify you.

4.3 Personal data we receive from you: any personal data you voluntarily 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, 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 data.

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 provide the relevant Personal Data to those platforms. Your Personal Data will then be subject to the privacy policies of those third-party trading platforms. Please 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 its 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 relevant 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 transaction involving the transfer or sale of assets, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other company 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, who operate on our website and may use cookies or similar technologies.

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 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 you to be identified when you revisit the website.

Please note that disabling certain site functions may cause parts of the Website to behave unexpectedly or stop working altogether.

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

8. Retention of Personal Data

We will 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 laws, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you agree, we will continue sharing your data for a further 12 months.

We periodically review the Personal Data we hold to confirm it is no longer required.

9. International Transfers

Your personal information may be transferred to other countries or international organisations. We take all necessary steps to protect your personal data and ensure you can effectively assert your rights and access legal recourse.

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

10. Security of Personal Data

We have implemented appropriate organisational 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 or 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 some circumstances, we may be legally or otherwise obligated to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot guarantee the security of any personal data you send to us via the internet.

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 operated or supervised by the Company. We are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.

11.2 When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. We also advise caution when providing any personal data to them.

12. Modifications to This Policy

This Policy may be updated at any time. If changes are made, we will notify you by posting the updated Policy 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 we collect, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the scope or types of processing applied to your personal information.

If you are an EEA resident, please refer to this page for information about the rights available to you in relation to your Personal Data. To exercise these rights, submit a written request to the email address below.

13.3 Access rights You have the right to access the Personal Data the Company holds and processes about you. Upon request, the Company will provide an electronic copy of your Personal Data and may charge a reasonable fee for additional copies. This right must be balanced against the rights and freedoms of others. Where fulfilling a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to rectification We may correct any inaccurate Personal Data we hold about you. You may also request that incomplete Personal Data be rectified, having regard to 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 required 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 where that processing is based on legitimate interests pursued by us or a third party; (e) the Personal Data are 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 an obligation imposed by 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 format and to request that it be transferred directly from the Company to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to the processing of Personal Data concerning you where that processing 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 process your Personal Data despite your objection. Concerning 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 to process 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 a relevant supervisory authority. Within the European Union, you may lodge a complaint with a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data. EU and member state laws may limit the rights set out in this section 13.

We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. 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, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, information requested under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover the administrative costs of responding, or we may decline to act.

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