Privacy Policy

1. The Scope

This policy explains what Personal Data the Company collects about natural individuals, 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 For the purposes of 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. We do not permit anyone under the age of 18 to use our platform, and we do not knowingly collect information from minors. If we become aware that data belonging to a person under 18 has been collected, 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 cases, we may ask you to provide personal data directly.

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 restrict your access to the website.

4. What Personal Data We Collect

The information collected is not 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 with a third-party online trading platform through us.

4.4 Personal information you share with 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 more details on the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following outlines the purposes and legal bases on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

The Company may also share personal data with third-party service providers that support our operations, including hosting and storage providers, IP address data processors, and user experience analytics services.

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 you have submitted to us directly to those platforms. Your Personal Data will then be governed by their respective privacy policies. 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 enhance and improve the products and services provided to its customers.

Where required to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.

We may share your Personal Data with potential investors, buyers, or lenders to the Company or any other group company in connection with a transaction — including the transfer or sale of Company or group assets — or as part of any 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 advertising networks and analytics companies. These third parties may use cookies or similar tracking technologies on our website.

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 presented to you. Cookies are also used for statistical and analytics purposes.

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 the browser is closed. Persistent cookies allow the Website to recognize you as a returning user and help restore your access on subsequent visits.

7.5 Please note that disabling cookies may cause certain features or functions on the Website to behave unexpectedly or not work at all.

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

8. Retention of Personal Data

We 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, regulation, or order.

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 confirm it is no longer required.

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 that 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@boldownholdance.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 or free from errors. We are also 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 reasonable control.

In some cases, we may be legally or otherwise obligated to share your Personal Data with third parties, including public authorities. In such situations, 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 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 sites or applications collect or process personal data. This Policy does not apply to any actions taken through such third-party 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 revised Policy will be posted on our website.

12.2 When significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless explicitly stated otherwise, 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 type of processing applied to your personal information.

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

13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. If confirmed, you have the right to 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 additional copies. If you request the data electronically, it will be provided in that format. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request is detrimental to another person's rights or freedoms, the Company may refuse or limit its compliance with that request.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You may also request that incomplete Personal Data be rectified, taking into account the purpose for which it is processed.

13.5 Right to Erasure You may request erasure of your Personal Data in any of 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 where that processing is based on legitimate interests pursued by us or a third party, and no overriding legitimate grounds exist; (e) the Personal Data have been unlawfully processed; or (f) erasure is required to comply with a legal obligation. 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 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 and review the Personal Data you have provided to the Company. 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 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. This right is not limited to profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where the processing relates to the establishment, exercise, or defence of legal rights, we may continue such processing. 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 refuse 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 prior to its withdrawal. You are entitled 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 individuals' fundamental rights in relation to the processing of Personal Data. Please note that EU and member state laws may limit the rights described in this section 13.

We will provide the information you are entitled to under Section 13 of this agreement within one month of receiving your request. If 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, information requested under your Section 13 rights will be provided at no cost. However, if a request is unjustified or excessive — particularly where requests are repetitive — we may charge a reasonable fee to cover administrative costs, 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 individual to provide adequate proof of identification.