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 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 Titan Sparvale (the "Website").
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods to keep you appropriately informed, and where specific details are needed, we'll provide them at the relevant time. We're also happy to address any questions you have about applicable legal limitations.
1. The Scope
This policy explains what 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 identified or identifiable natural persons. An identifiable natural person is someone who can be identified either directly or 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 and are not designed for anyone under the age of 18. We do not knowingly collect information from persons under 18, nor do we knowingly permit them to use our services. If we become aware that such information 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. 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 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 restrict your access to the website.
4. What Personal Data We Collect
4.1 This includes your online activity log and traffic data, covering:
- 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
The information collected is not personal in nature 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 with a third-party online trading platform through us.
4.4 Personal information you provide directly to 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.
5.2 The Company may only process Personal Data concerning you where a valid legal basis exists. The legal grounds on which the Company may rely to process your Personal Data are:
- By submitting personal data through the Website, you consent to its processing for one or more specified purposes, including its transfer to a third-party trading platform.
- In some cases, we or a third party may need to process your data to serve a legitimate interest — such as improving our Services or defending legal claims.
- Processing must meet an obligation of law.
For more information about the processing required to protect legitimate interests, please 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:
Scope
Legal Basis
At your request, we may collect and share your personal data with third-party companies to facilitate access to digital trading.
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 is required to address any questions you may have about the Services.
Processing of personal data may be required to serve the legitimate interests of the Company or a third party.
Personal Data is processed to meet applicable legal, administrative, or judicial obligations.
To ensure compliance with legal obligations, processing is required.
4. To Improve Our Services
We may use personal data to improve Our Services, including crash reports and malfunction data collected in connection with the Services.
Processing data is necessary to serve the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing of personal data may be necessary to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
This includes back-office operations, business development, strategic decision-making, and oversight functions.
Processing of personal data may be necessary to serve the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas.
Processing is required to serve the legitimate interests of the Company or a third party.
8. To protect our rights, interests, and assets, 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 applicable laws, regulations, agreements, and any related conditions, terms, or policies.
Processing data is necessary to protect the legitimate interests of the Company or a relevant third party.
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, IP address data handlers, 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 Personal Data you have submitted to us directly to those platforms. Your Personal Data will be governed by their respective privacy policies and may be shared with more than one trading platform.
6.3 The Company may share Personal Data with related entities or business partners to support the development and improvement of its products and services.
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 transaction such as the transfer or sale of company assets, a 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 personalise the products and services most relevant to you. Cookies are also used for statistics 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 your browser is closed. Persistent cookies allow the Website to recognise you as a returning user and enable seamless access on subsequent visits.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are required to access the features you've requested and navigate our website. They enable your device to download and stream data, delivering the information, products, and services you've asked for. This allows you to move through the website, use its features, and return to previously visited pages.
Additional Information
Cookies collect personal data — such as your username and last login date — to verify that you are logged in. They are deleted when you close your browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies recognize you each time you visit our site and store your preferences.
Additional Information
These cookies persist until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on site performance and to carry out analysis that helps us improve your experience.
Additional Information
Cookies store anonymous data that is not linked to any identifiable natural person. Session cookies are removed when you close your browser; others remain valid indefinitely.
7.4 If cookies are blocked or removed, you will need to adjust your browser settings. The links below cover the process for some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note that disabling cookies may cause some or all Website features 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
The Company 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 laws, regulations, or orders.
8.2 We will share your information with third-party trading platforms for 12 months. If you consent, 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
9.1 Your personal data may be transferred to other countries or shared with international organizations. The Company takes all necessary steps to protect the personal data you provide and to ensure that you retain the right to assert your rights and access effective legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area):
- Transfers to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- This transfer is made under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
- This transfer was carried out in accordance with standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
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@titansparvale.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 without error. We are not liable for any 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 share your Personal Data with 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 ensure 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 under the Company's supervision. We are not responsible for how personal data is collected or processed by them. 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
12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised 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 may request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete 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 information on your rights regarding your Personal Data. To exercise any of these rights, please contact us at the email address below.
13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where such processing is confirmed, you have the right 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. Data will be supplied electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. Where 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 any inaccurate Personal Data it holds about you. You have the right to request the rectification of incomplete Personal Data concerning you, taking into account 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, on grounds specific to your 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 are unlawfully processed; or (f) erasure is required to fulfil a legal obligation of 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. Once a restriction is in place, 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 this right does not affect your right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.
13.8 Right to object You have the right to object at any time to the processing of your Personal Data 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 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 such processing. Concerning direct marketing, you have the right to object at any time to the processing of your Personal Data 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 before its withdrawal. You have the right to lodge a complaint with your supervisory authority. Within the European Union, you may also 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. Please note that applicable 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 additional months. We will notify you of any such extension, along with the reasons, 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 providing the information or carrying out the requested action. We may also decline to act on such requests.
13.12 If we have reasonable doubts about the identity of the person submitting a request, we may ask that person to provide sufficient means of verifying their identity.
Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.
Titan Sparvale 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@titansparvale.com