Privacy Policy
Our beginning
We – referred to as 'We' or 'Our' – are committed to protecting your personal data and your privacy.
This privacy policy is designed to explain how we collect, store, process, and use the information you provide in connection with the website Thorn Kapsted (hereinafter the 'Website').
We commit to following these principles:
Transparency in collecting and processing your personal data:
We ensure that you are always well-informed so you can make conscious choices about how your data is used on the website or when you interact with third-party platforms. We use various methods to provide you with accurate and timely information about the processing of your data.
If we need to give you specific information, we ensure it is delivered at the right time and place.
We are also available to answer questions or provide clarifications, within the current legal framework. You can reach us at: [email protected]
Processing personal data only for the purposes stated in this policy:
We may process your information to make the website available, connect you to third-party trading platforms ('the Services'), improve the user experience, develop the platform, protect our rights, carry out administrative processes, and fulfil legal requirements.
We also process information to better understand your needs and preferences.
Resources to uphold your rights:
We allocate significant resources to ensure you can exercise your rights as a data subject. You may at any time request access to, rectification of, erasure of, or restriction of processing of your data, or request data portability. We will respond in accordance with applicable law.
Protection of your personal data:
While we cannot guarantee absolute security, we use modern security methods and measures to protect your information and will continue to improve these.
Our full privacy policy
1. Scope
This policy describes the types of data we collect, how we process it, share it with third parties, and the security measures we apply.
'Personal data' means any information that can be linked to an identified or identifiable person. 'Processing' means any operation such as collection, storage, use, sharing, alteration, or deletion.
Our services are intended for a general audience and are not directed at individuals under 18. We do not knowingly collect information from minors. If we discover such information has been recorded, we will delete it immediately.
2. When do we collect information?
We collect data when you use our services, visit the website, or interact with our channels. Some information you provide directly; other information is collected automatically through analysis of your activity or via third-party partners.
3. No obligation to provide data – but consequences
You are not required to provide us with information. However, without certain data, we may not be able to offer you all our services or provide you with full access to the website.
4. What types of information do we collect?
This may include activity logs, IP addresses, timestamps, language, browser type, device information, and error logs. Some of this may not directly identify you and is therefore not considered personal data.
Information you provide directly: name, phone number, email address when you contact us or use the platform.
5. Purposes of processing and legal basis
Thorn Kapsted processes information only when we have a legal basis, for example, to provide services, improve the experience, protect your data, or comply with legal obligations.
- You have given consent to the processing of your personal data for specific purposes. This applies when you consciously share information via the website so that we can forward it to a third-party trading platform.
- Processing is necessary for the legitimate interests pursued by Thorn Kapsted or a third party. For example, this may include improving our services or handling legal claims.
- Processing is necessary for compliance with a legal obligation to which Thorn Kapsted is subject.
If you would like a further explanation of how the processing of your personal data serves the legitimate interests of Thorn Kapsted or a third party, you can contact us at any time by email.
Below is an overview of why we may process your information, along with the legal bases:
| Purpose | Legal Basis | |
| 1 |
To forward your information to a third party upon request to participate in digital or trading activities. We may collect information to forward it if you explicitly request this. |
Your consent to the processing for one or more specified purposes. |
| 2 |
To respond to your enquiries and requests Processing of information is necessary to handle questions you may have about our services. |
Necessary for the legitimate interests of the company or a third party. |
| 3 |
To comply with legal obligations or regulatory requirements We process data to ensure compliance with statutory requirements. |
Necessary for compliance with a legal obligation. |
| 4 |
To improve our services This may include analysing error logs or other reports to optimise the platform. |
Necessary for the legitimate interests of the company or a third party. |
| 5 |
To prevent fraud and misuse of the services |
Necessary for the legitimate interests of the company or a third party. |
| 6 |
To perform and maintain operational activities that support the provision of services This may include back-office functions, business development, strategic planning, and internal controls. |
Necessary for the legitimate interests of the company or a third party. |
| 7 |
To perform analyses and statistical assessments We use statistical methods and analyses to make better decisions and improve the platform. |
Necessary for the legitimate interests of the company or a third party. |
| 8 |
To protect our and third parties' interests, rights, and assets, including legal claims We may process information to defend rights and interests in accordance with applicable law, agreements, and terms. |
Necessary for the legitimate interests of the company or a third party. |
6. Transfer of personal data to third parties
Thorn Kapsted may share your information with third-party providers who assist with storage, hosting, IP information, user experience analysis, research, and other technical or diagnostic services.
If you request it, we may also transfer certain information to third-party trading platforms. In such cases, they will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.
Thorn Kapsted may also share information with affiliated companies and business partners who help improve the quality of our services.
We may disclose information to public authorities if necessary to protect our or a third party's interests, rights, or assets, including in connection with legal proceedings.
Information may also be shared with potential buyers, investors, or lenders in connection with a merger, acquisition, reorganisation, or bankruptcy proceedings.
7. Cookies and third-party services
We use certain third-party services, such as analytics and advertising providers. These may use cookies or similar technologies, governed by their own policies.
A cookie is a small text file stored on your device when you visit the website. It may collect information about usage patterns, preferences, and technical data, and is used to improve your experience, remember settings, and deliver more relevant content.
We may use both session cookies (which are deleted when the browser is closed) and persistent cookies (which remain on your device until they expire or are manually deleted).
Types of cookies:
| Type | Purpose | Additional Information |
| Strictly Necessary Cookies | These are essential for navigating and using the website's features, as well as downloading or streaming content without interruption. | They may contain login status and are automatically deleted when you close the browser (session cookies). |
| Functional Cookies | Help the website remember choices and preferences when you return. | Remain on the device until they expire or are manually deleted. |
| Performance and Analytics Cookies | Used to collect statistics and measure performance, so we can improve the user experience and test new features. | Collect only anonymised data. Some are deleted at the end of the session, others may last longer. |
Blocking and deleting cookies
You can change your browser settings to block or delete cookies. Here are links to instructions for the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some features on the website may stop working if you block cookies.
NOTICE REGARDING ONLINE TRACKING
This service currently does not support 'Do Not Track' signals.
8. Storage of personal data
Thorn Kapsted will store your information for as long as necessary for the purposes described in this policy, or as required by law, regulation, or authority.
If you have consented, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension upon renewed consent.
We regularly review stored information to ensure it is not kept longer than necessary.
9. Transfer of personal data to third countries or international organisations
Your personal data may be transferred to a third country (outside the UK/EEA) or to international organisations. In such cases, Thorn Kapsted will implement necessary safeguards to ensure the information is protected and that you retain your rights and effective remedies.
If you are resident in the UK/EEA, such safeguards will apply if one of the following criteria is met:
- The transfer is to a third country or international organisation that the UK/European Commission has recognised as having an adequate level of data protection.
- The transfer is carried out on the basis of a legally binding and enforceable instrument between public authorities or bodies.
- The transfer is based on standard data protection clauses adopted by the UK/European Commission. You can find these clauses on the Commission's website.
If you would like more information about the safeguards we use when transferring personal data, you can contact us at: [email protected]
10. Protection of personal data
We use technical and organisational security measures to protect personal data against unauthorised access, alteration, loss, or destruction. These measures are adapted to the risk associated with the processing.
We cannot guarantee absolute security for data transmission over the internet. Thorn Kapsted disclaims liability for indirect or incidental damages that may arise as a result of data loss or unauthorised access beyond our reasonable control.
In some cases, we may be legally obliged to share information with public authorities. Our level of control over the protection of the information may then be limited.
11. Links to third-party websites
The website may contain links to external websites or applications operated by third parties. Thorn Kapsted has no control over these and is not responsible for their processing of personal data. We recommend that you always read their privacy policies before providing any information.
12. Your rights regarding personal data
You have the right to request access to the information we process about you, to request rectification of inaccuracies, to request erasure of data that is no longer necessary, and to restrict or withdraw consent for specific processing activities.
Right of access
You have the right to obtain confirmation as to whether Thorn Kapsted processes personal data concerning you. If we do, you have the right to access that data and information about: the purposes, categories of data, recipients (including in third countries), the storage period, your rights, the right to lodge a complaint, and the safeguards applied for transfers.
You may receive a copy of the data being processed. If you request further copies, we may charge a reasonable fee. If the request is made electronically, you will normally receive the data in a commonly used electronic format.
The right of access shall not adversely affect the rights and freedoms of others. If this occurs, we may restrict access or refuse the request.
Right to rectification
You can request that Thorn Kapsted rectify inaccurate or incomplete personal data concerning you. If necessary, you may supplement it with a supplementary statement.
Right to erasure ('right to be forgotten')
You have the right to request the erasure of your data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the processing is unlawful. We will respond in accordance with applicable law.
Right to erasure ('right to be forgotten')
This right applies if: (a) the personal data is no longer necessary for the purpose it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or a third party's legitimate interests, and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the data has been unlawfully processed; or (f) the data must be erased to comply with a legal obligation under UK or EU law.
The right does not apply if the processing is necessary (a) for compliance with a legal obligation, or (b) for the establishment, exercise, or defence of legal claims.
Right to restriction of processing
You may request that we restrict the processing of your data if: (a) you contest the accuracy, for a period enabling us to verify; (b) the processing is unlawful, but you oppose erasure and request restriction instead; (c) we no longer need the data, but you require it for legal claims; (d) you have objected to processing, pending verification of our legitimate grounds; (e) the data is processed for direct marketing, including profiling.
If processing is restricted, the data may only be used with your consent, for legal claims, to protect the rights of others, or for reasons of important public interest.
Right to data portability
You have the right to receive the personal data you have provided to us, in a structured, commonly used, and machine-readable format. You may also request that we transmit the data directly to another controller, where technically feasible, and where the processing is based on consent or contract and carried out by automated means.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to object
You may object to the processing of your data when the processing is based on legitimate interests. This also applies to profiling. We will then cease processing, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.
You may also object at any time to processing of your data for direct marketing, including profiling related to such marketing.
Right to lodge a complaint with a supervisory authority
You may lodge a complaint with the Information Commissioner's Office (ICO) or another supervisory authority within the UK/EEA if you believe that the processing of your personal data infringes data protection law.
We will respond to requests to exercise rights within one month of receipt. This period may be extended by up to two further months if necessary, depending on the complexity and number of requests. You will be informed of the reason for the delay.
Information relating to the exercise of rights will be provided free of charge, unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse the request.
Thorn Kapsted may request additional information to confirm your identity if we have reasonable doubts.
13. Updates to this policy
We reserve the right to update this privacy policy. Changes will be published on the website, and we will notify you of material updates in a clear manner. Unless otherwise stated, changes take effect upon publication of the updated policy.