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 known as "We", "Us" or "Our") are committed to protecting your personal data and privacy. This Privacy Policy explains how we collect and store the information you provide through the website Sour Orange (the "Website").
We want to ensure you can make informed decisions about how your Personal Data is used and processed. We use various methods to keep you informed and relevant. Where we believe you need specific details, we'll provide them at the right time. We're happy to answer any questions about legal limitations that may apply.
1. The Scope
This policy describes the types of Personal Data the Company collects from individuals and how it processes, shares, and protects such data.
1.2 This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or recognised through a combination of information we hold or can access.
1.3 The Policy defines "processing" as any activity involving the use or collection of Personal Data. This encompasses managing, organising, and storing Personal Data.
1.4 Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect information from anyone younger than 18, nor do we intentionally permit such individuals to use our services. Should we become aware of any information relating to children, we will delete it promptly.
2. What Personal Data Do We Have on You
When you access our service, channels, or website, we collect Personal Data. We may also request your Personal Data in certain instances.
2.2 In other cases, we collect your Personal Data by analysing how you use our Services and 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. However, in certain circumstances, if you do not supply Us with the necessary personal data, We may be unable to provide the Services or allow users to access the website.
4. What Personal Data We Collect
4.1 This includes details of your online activity log and traffic data, including:
- 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 you collect is not personal information and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you provide to us at your own discretion when you connect to a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party trading platforms: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 Your personal data is processed by the company for the purposes set out in this section, in accordance with the applicable legal basis.
5.2 The Company cannot process your Personal Data without a legal basis. The following legal grounds permit the Company to process your Personal Data:
- You have consented 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 your data to pursue their legitimate interests, such as improving Our Services or defending legal claims.
- Processing must meet an obligation of law.
5.3 Contact us by email for further details on the processing required to protect our legitimate interests.
5.4 Below is a list of the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
To provide your personal information to third parties at your request to access digital trading
If you ask us to, we may request Personal Data from you to share it with third-party companies.
You've consented to the processing of your personal data for one or more of the reasons outlined.
2. To respond to your enquiries, requests or concerns
We require your Personal Data to assist with any questions you may have about our Services.
We need to process data to protect the legitimate interests of the Company or a third party.
We process your Personal Data to comply with applicable legal, administrative, and judicial obligations.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services, we may use your Personal
Data to improve Our Services. This includes, among other things, crash and malfunction reports we collect relating to the Services.
The Company or a third party's legitimate interests require the processing of personal data.
5. To stop fraud and misuse of Our Services.
We need to process personal data to protect the legitimate interests of the Company or a third party.
6. To perform and manage actions in accordance with Our Services requirements
This includes back-office functions, business development activities, strategic decision-making, oversight mechanisms, and similar activities.
The Company or a third party has a legitimate interest that requires the processing of your data.
7. To conduct analysis, such as statistical analysis
To inform our decision-making on various matters, we use a range of analytical techniques, including statistical methods.
We need to process personal data to pursue the legitimate interests of the Company or a third party.
To protect our assets, rights and interests, as well as those of third parties, we may process Personal Data in accordance with applicable laws, regulations, agreements, and our terms and policies.
The Company or a third party must have a legitimate interest in processing your data.
6. Transfer of Personal Data to Third Party
The Company may also share Personal Data with third-party service providers, such as hosting, storage, and IP address analysis providers, to support user experience analysis and related services.
6.2 You can also request that we share your Personal Data with third-party trading platforms. In such cases, we will provide your Personal Data to these trading platforms, whose use of your information is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
6.3 The Company may share Personal Data with related entities or business partners to obtain the resources needed to enhance and improve its products and services for customers.
6.4 If disclosure is necessary to protect the rights of third parties or assets, the Company may share Personal Data with 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 group company, should such a transaction take place (including the transfer or sale of Company assets or those of any group company) or as part of any merger, restructuring, consolidation, or insolvency involving the Company or any other group business.
7. Cookies and Services from Third Parties
We may use third-party services, such as advertising and analytics providers, which may also use cookies or similar technologies.
7.2 Cookies are small text files stored on your device when you visit our website. We use them to understand your preferences and browsing behaviour, enhance your experience, remember your settings, and tailor products and services to your interests. Cookies also help us gather statistical and analytical data.
7.3 We use two main types of cookies on our website. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies, by contrast, remain on your device after you close your browser. We use them to recognise you as a returning user and to help you navigate the website more easily on future visits.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and navigate our website. They provide the information, products and services you've asked for.
They're required for your device to download and stream data, allowing you to navigate the site, use its features, and return to previously visited pages.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm you're logged in to the site. They're automatically deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and to save your preferences.
Additional Information
They remain valid until their expiry date and are retained even after you close your browser.
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and analytics, helping us improve your experience on the website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are removed when you close your browser, whilst others remain indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, adjust your browser's settings. Below are links to help you with the process for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain features or the entire Website's functionality may not work as expected in these circumstances.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing, as described in this Policy, or for longer periods as permitted by applicable law, regulations, and policies.
We'll share your information with third-party trading platforms for 12 months. If you consent, we'll continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it's no longer required and delete it accordingly.
9. International Transfers
Your personal information may be transferred to other countries, including to third countries or international organisations. We take all necessary steps to protect your personal data and ensure that you can exercise your rights and access effective legal remedies.
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 adequate protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made in accordance with a legally binding and enforceable agreement between public entities or authorities as set out in Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.
The Company can provide details on the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. For more information, please email: support@testprodsource100b.best
10. Security of Personal Data
We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.
10.2 We cannot guarantee that your Personal Data will be kept secure without error. We are also not responsible for any indirect, incidental, or consequential damages that arise from the use or disclosure of your Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by third parties, or any other cause beyond our control.
10.3 If we're required by law or other circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we must do so. We cannot guarantee the security standards those third parties apply to your Personal Data in these situations.
Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the safety of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
The website contains links to third-party sites and applications that are not operated by the Company. We do not supervise these external platforms and are not responsible for how they collect or process your Personal Data. This Policy does not apply to activities conducted through such third-party sites or applications.
11.2 Before accessing or using any third-party websites or apps, we recommend that you read their privacy policies. We also suggest that you review what Personal Data you provide to them.
12. Modifications to This Policy
This Policy may be updated at any time. Should we make changes, we will notify you by posting the updated Policy on our website.
12.2 Additionally, when we make significant changes to this Policy, we will attempt to notify you using methods we consider appropriate and will publish an announcement on our website.
12.3 Unless explicitly stated otherwise, any amendments will take effect following publication of the revised Policy.
13. Your Rights
You have the right to ask us to verify that your Personal Data is accurate, correct any errors, and delete any Personal Data we no longer need. You can also restrict how we process your information.
If you're resident in the EEA, please refer to this page for information on your rights regarding your Personal Data. You may exercise these rights by emailing the address below.
13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. If accurate, you may 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 made available electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights or freedoms, the Company may refuse the request or limit its ability to fulfil it.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data relating to you be corrected, having regard to the purpose of processing.
13.5 Right to Erasure The following reasons are applicable: (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 legal basis to process; (c) You object at any time, for reasons specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by third parties; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to comply with a lawful obligation. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law under European Union or Member State law; or (b) to establish, exercise or defend legal rights.
13.6 Processing restrictions If you believe your Personal Data is inaccurate, you can request that the Company restrict its processing. Once Personal Data is restricted, it may only be retained if you provide consent, or where necessary to establish, exercise, or defend legal rights, or to protect the rights of another individual, or where there is a substantial public interest reason within the European Union or a Member State.
13.7 Right to data portability If processing is carried out by an automated system and is based on your consent or a contract you are party to, you have the legal right to access and review your Personal Data held by the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your right to erasure remains unaffected by exercising your data portability rights. The right to data portability does not prejudice the rights or freedoms of others.
13.8 Right to challenge You have the right to object to any processing of your Personal Data based on the Company's or a third party's legitimate interests at any time. This includes objections to profiling based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may only continue if you cannot show that our grounds are outweighed by your rights, freedoms, interests, or the need to establish, exercise or defend legal claims. Regarding direct marketing, you may object to the processing of your Personal Data at any time.
13.9 Right to refuse consent You may revoke your consent for Us to process your Personal Data at any time. This will not affect the legality of any processing that relied on your consent before its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by an EU Member State to protect the fundamental rights of individuals regarding Personal Data processing within the European Union. EU and Member State laws may limit your rights concerning your Personal Data, as set out in this section 13.
13.10 We will provide you with the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. The timeframe may be extended to up to two months if necessary, depending on the nature and volume of your request. We will notify you of any extension and the reasons for it within one month of receiving your request.
We will provide the information you request under section 13 free of charge, provided this complies with section 13 of the law. However, if your request is unjustified or excessive—particularly if repeated—we may charge a reasonable fee to cover our administrative costs. In such cases, we may also choose not to proceed with your request.
13.12 If we have concerns about verifying the identity of the person submitting your request, we may ask them to provide reasonable means of identification.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Sour Orange 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@testprodsource100b.best