TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Lyric Vaultmere (the "Website").
We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods to give you relevant information, and when we believe you need specific details, we will provide them at the appropriate time. We are also happy to answer any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy explains the types of Personal Data the Company collects from natural persons, and how it processes, shares with third parties, and secures that data.
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 indirectly by combining additional information we hold or can access.
1.3 Under this Policy, "processing" means any operation that uses or collects 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 any person 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 We collect Personal Data when you use our services and channels or visit our website. 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. In certain circumstances, however, withholding such data may prevent Us from delivering the Services or granting you access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and traffic data, such as:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
4.2 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 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 complete trades: 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 described in this section, in accordance with the applicable legal basis.
5.2 The Company cannot use your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are:
- You have given consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to serve a legitimate interest, such as improving Our Services or defending legal claims.
- Processing must meet an obligation of law.
5.3 Email us for more details on the processing necessary to protect our legitimate interests.
5.4 We may use the information you provide for the following reasons and on the following legal grounds:
Scope
Legal Basis
1. To share your personal information with third parties at your request to enable access to digital trading
If you request it, we may collect Personal Data from you to forward it to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data helps us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed to meet legal obligations or to comply with administrative, judicial, or legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. To perform and manage activities aligned with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We apply various analytical techniques, including statistical methods, to make decisions on different issues.
Processing is necessary for the legitimate interests of the Company or those of a third party.
8. To safeguard our assets, rights and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements, and any terms, conditions or policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party providers who deliver services to us, including hosting and storage providers, IP address information, and the analysis of user experiences.
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 Personal Data you supply to us to those third-party trading platforms, and your Personal Data may be shared with multiple trading platforms. Their use of your Personal Data is governed by their own privacy policies.
6.3 The Company may share Personal Data with related entities or business partners. This gives the Company the resources to enhance and improve the products and services it provides to its customers.
6.4 To protect the rights of third parties or to safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
6.5 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 any such transaction (including the transfer or sale of assets belonging to the Company or another 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 and analytics companies. These companies may also use cookies or similar technology.
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 enjoy. 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 period of time after you close your browser. They help the Website recognize you as a returning user and make it easier for you to return to the site.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for accessing the features you request and navigating our website. They deliver the information, products, and services you ask us to provide.
They are required for your device to download and stream data, allowing you to move around the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect personal data such as your username and last login date to confirm that you are logged in. Session cookies are erased once you close your web browser.
The type of cookie
Functionality Cookies
Scope
Cookies recognize you on each visit and save your preferences.
Additional Information
They remain valid until their expiry date and are retained even after you close the browser.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistics on how the site performs and to help improve it. They also allow us to analyse the way our website is used.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, adjust your browser's settings. The links below explain the process for a few of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note 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 fulfill 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 personal data with third-party trading platforms for a period of 12 months. If you consent, 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 information may be transferred to other countries, meaning your personal data may be sent to a third country or to international organizations. Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of 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 transferred 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 under a legally binding and enforceable agreement between public bodies or authorities, in line 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
9.3 You may request details about the security measures the Company uses to protect your Personal Data transferred to third-party countries or international organisations. Email us at: support@lyric-vaultmere.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational 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, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
10.3 Where required by legal obligations or other circumstances beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these situations, we cannot control the level of security applied to your Personal Data by those third parties.
10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of Personal Data you send to Us through the internet.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications that are not under the Company's control. We are not responsible for how these sites or applications collect or process Personal Data. This Policy does not apply to any actions taken through them.
11.2 When accessing any third-party website or app, we recommend reviewing its privacy policy before deciding to use it, and before sharing any Personal Data with the third party.
12. Modifications to This Policy
12.1 We may update this Policy at any time. If we make changes, We will notify you by posting the updated Policy on our website.
12.2 We will also notify you of significant changes to this Policy through the methods we consider appropriate and will post an announcement on our website.
12.3 Unless otherwise specified, any amendments take effect once the revised Policy is published.
13. Your Rights
13.1 You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the types of processing applied to your Personal Data.
13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, email the address below.
13.3 Right of access The Company can confirm whether your Personal Data is being processed. If it is, you may access that 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. Where 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. If a request adversely affects 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 rectification of any incomplete Personal Data concerning you, taking into account the purpose of processing.
13.5 Right to Erasure The following grounds apply: (a) 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, at any time and for reasons specific to your situation, to the processing of Personal Data about yourself based on legitimate interests pursued by Us or by a third party; (e) Personal Data have been 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 fulfil a legal obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.
13.6 Restriction of processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where Personal Data is restricted, it may only be retained with your consent, to establish, exercise, or defend legal claims, 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 the right to data portability does not affect your rights under the right to erasure. The right to data portability shall not adversely affect the rights and freedoms of others.
13.8 Right to object You may object at any time to any use 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 establish compelling legitimate grounds for processing your Personal Data, we may continue only if those grounds override your interests, rights, and freedoms, or relate to the establishment, exercise, or defense of legal claims. Regarding direct marketing, you have the right at any time to object 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 lodge a complaint with 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 in relation to Personal Data concerning you, as set out in this section 13.
13.10 We will provide the information you request 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. If an extension is needed, we will notify you within one month of receiving your request, together with the reasons for the delay.
13.11 Provided it does not conflict with section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly when repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or carrying out the requested action. We may also decline to act.
13.12 If we have doubts about the identity of the person submitting your request, we may ask that person to provide reasonable means of identifying themselves.
This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.
Lyric Vaultmere 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@lyric-vaultmere.com