Privacy Policy

1. The Scope

1.1 This policy explains what Personal Data the Company collects about individuals, how it is processed, when it may be shared with third parties, and the measures in place to keep it secure.

1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through a combination of additional information that we hold or can reasonably access.

1.3 For the purposes of this Policy, "processing" means any activity that involves the use or collection of Personal Data. This includes the handling, organisation, and storage of Personal Data.

1.4 Our services are intended for a general audience and are not meant for anyone under the age of 18. We do not knowingly collect or request information from anyone younger than 18. We also do not knowingly permit such individuals to use our services. If we become aware that we hold information relating to a child, we will delete it as soon as reasonably possible.

2. What Personal Data Do We Have on You

2.1 When you use the service and its channels, or visit our website, we collect Personal Data. In certain circumstances, we may ask you to provide your Personal Data.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide us with any Personal Data. In some circumstances, however, choosing not to do so may prevent us from providing the Services or may limit users’ access to the website.

4. What Personal Data We Collect

4.2 The information you collect does not constitute personal information 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 to a third-party online trading platform through Us.

4.4 Personal information that you provide directly to third-party platforms to enable trading, including your full name, address, telephone 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 and in line with the applicable legal basis.

5.3 Please contact us by email for more information about the processing required to protect legitimate interests.

5.4 The following sets out the reasons and legal bases 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 that support our operations, including hosting and storage providers, IP address information services, and user experience analytics providers.

6.2 You may also ask us to share specific Personal Data about you with third-party trading platforms. In these cases, we will provide the Personal Data you have given us to those third-party trading platforms. Their use of your Personal Data will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources it needs to enhance and improve the products and services it offers to its customers.

6.4 Where it is necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local or other official authorities.

6.5 We may also disclose your Personal Data to prospective investors or purchasers, or to lenders of the Company or any other company within the group, if such a transaction is contemplated or takes place (including any transfer or sale of assets owned by the Company or any other group company), or as part of any merger, restructuring, consolidation or insolvency process involving the Company or any other business in the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, including advertising providers on our website and analytics companies. These providers may also use cookies or similar technologies.

7.2 Cookies are small text files stored on your device each time you visit or access the website. They help collect information about your preferences and browsing behaviour so we can improve your experience, remember your settings, and tailor products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for a short time, usually until you close your browser. Other cookies are persistent cookies. These stay on your device for a period after your browser has been closed. They help the Website recognise you as a returning user and make it easier for you to access the website again.

7.5 Please note that, if this occurs, some or all of the Website’s functions and features may not work as expected.

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

8. Retention of Personal Data

8.1 The Company will keep your Personal Data only for as long as needed to fulfil the purpose for which it is processed, as set out in this Policy, or for any longer period allowed under applicable law, regulations, policies, or binding directions.

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

8.3 We regularly review the Personal Data we hold to make sure it is no longer required.

9. International Transfers

9.1 Your personal information may be transferred to other countries (in other words, your personal data may be shared with recipients in another country or with international organisations). The Company takes all reasonable steps to protect the Personal Data you provide and to ensure that data subjects are able to exercise their rights and have access to effective legal remedies.

9.3 The Company may provide information on the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Please email: support@marula-capstead.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. These measures are designed to prevent the accidental or unlawful destruction, loss or alteration of Personal Data.

10.2 While we take reasonable steps to protect your Personal Data, we cannot guarantee that its security will be maintained without fail. We are also not liable for any indirect, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other circumstances beyond our control.

10.3 Where we are required by law, or due to circumstances beyond our reasonable control, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we are not able to control how those third parties protect your Personal Data.

10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. 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 include links to third-party websites and applications. These websites and applications are not under the Company’s control or supervision. We are not responsible for how these websites or applications collect or process Personal Data. This Policy does not apply to any actions taken on or through such websites or applications.

11.2 Before accessing or using any third-party websites or apps, we recommend that you read their privacy policies carefully and consider whether you want to share any Personal Data with them.

12. Modifications to This Policy

12.1 We may update this Policy from time to time. If any changes are made, we will let you know by publishing the revised Policy on our website.

12.2 In addition, if we make material changes to this Policy, we will endeavour to notify you using the communication methods we consider appropriate and will publish a notice on our website.

12.3 Unless stated otherwise, any changes will take effect once the updated Policy has been published.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data we hold about you, correct any errors, and delete any Personal Data that we no longer require. You may also limit the scope of how your personal information is processed.

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

13.3 Access rights The Company may verify the accuracy of the Personal Data it processes about you. Where such processing takes place, you are entitled to 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 any additional copies. If you request it, the data will be provided electronically. Your right of access to Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can comply.

13.4 Right to rectification The Company may correct any inaccurate Personal Data. You also have the right to request that incomplete Personal Data relating to you be corrected, taking into account the purpose for which it is being processed.

13.5 Right to Erasure This right may apply in the following circumstances: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object, on grounds relating to your particular situation, to the processing of your Personal Data where that processing is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be deleted 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 requiring processing under applicable law; or (b) to establish, exercise, or defend legal rights.

13.6 Restrictions on processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request a restriction, the Personal Data may then only be retained with your consent, for the establishment, exercise or defence of legal rights, to protect the rights of another natural person, or where there is an overriding reason of substantial public interest under applicable law.

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 legal right to receive the Personal Data you have provided to the Company and to review that information. You may also request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. This right also does not override the rights or freedoms of any other person.

13.8 Right to object You may object at any time to the use of your Personal Data where processing is based on the legitimate interests of the Company or a third party. This also applies to profiling carried out on that basis. Where we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue unless you are able to show that your rights, freedoms or interests override those grounds, or that the processing is required for the establishment, exercise or defence of legal claims. In relation to direct marketing, you have the right to object at any time to the processing of your Personal Data.

13.9 Right to withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before it was withdrawn. You also have the right to submit a complaint to the relevant supervisory authority. You may lodge a complaint with a supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data. Applicable laws may limit your rights in respect of your Personal Data, as set out in this section 13.

13.10 We will provide the information you request in line with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature of the request and the number of requests received. If an extension applies, we will inform you within one month of receiving your request and explain the reasons for the delay.

13.11 Provided this does not conflict with the provisions of section 13 of the law, any information you request in exercising your rights under section 13 will be supplied free of charge. If a request is unjustified or excessive, particularly where it is repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act.

13.12 If we have any concerns about the identity of the individual who submitted your request, we may ask the person making the request to provide reasonable proof of identity.