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 kept secure.

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 and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals 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. In certain instances, we may also request personal data directly from you.

2.2 In some cases, we collect your personal data by analysing how our Services or 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 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 non-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 provide directly to third-party platforms to facilitate trading: this 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 set out in this section, in accordance with the applicable legal basis.

For full details on the processing carried out to protect our legitimate interests, please contact us by email.

5.4 The following sets out the purposes 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, including hosting and storage providers, as well as companies that analyse user experience and IP address information.

6.2 You may also request that we share specific personal data about you with third-party trading platforms. Where you make such a request, we will provide the relevant personal data to those platforms accordingly. Your personal data shared in this way will be subject to the privacy policies of the respective third-party trading platforms. Please note that your personal data may be shared with more than one 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 customers.

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 group company, in connection with a transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or bankruptcy affecting the Company or any other business 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, who operate on our website and may use cookies or similar 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 you see. Cookies are also used for statistics and analytics purposes.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and 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 help you resume your session when you revisit the site.

7.5 Please note that disabling cookies may cause some or all Website features to behave unexpectedly or not function at all.

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

8. Retention of Personal Data

We will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will do so 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 organisations. The Company takes all necessary steps to protect your personal data and ensure that you retain the ability to exercise your rights and access effective legal remedies.

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, contact us at: support@northaccruance.com

10. Security of Personal Data

We have implemented appropriate organisational 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 without error at all times. We are 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.

10.3 In certain circumstances, legal or other obligations beyond our control may require us to disclose your Personal Data to third parties, such as public authorities. In these situations, we have no control over how those third parties protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be completely secure. The Company cannot guarantee 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 that are not under the Company's supervision. We are not responsible for how those 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, we recommend reading their privacy policies before accessing or using their services. We also advise that you exercise caution when providing any personal data to them.

12. Modifications to This Policy

This Policy may be updated at any time. Any changes will be reflected in the updated Policy 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 otherwise specified, 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 being collected, to have any inaccuracies corrected, and to request deletion of any Personal Data we no longer require. You may also restrict the scope of processing of your personal data.

If you are an EEA resident, please refer to this page for details on your rights in relation to your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights You have the right to verify whether the Company is processing your Personal Data and, if so, to access it. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. This right must not conflict with the rights and freedoms of others. Where fulfilling a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.

13.4 Right to rectification You have the right to request correction of any inaccurate Personal Data held about you. Where Personal Data is incomplete, you may also request that it be completed, having regard to 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 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 by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased 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 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. Where 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 natural person, or where there is a substantial public interest under European Union or Member State law.

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 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 solely on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the 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 to process your personal data. 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 withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that point. You have the right to lodge a complaint with your supervisory authority. Within the European Union, you may contact the supervisory authority established by your member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that EU and member state law 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 necessary, this period may be extended by up to two months, depending on the complexity or volume of requests. 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 provided in response to a request made under your section 13 rights will be provided free of charge. Where a request is unjustified or excessive, particularly where requests are repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or notifying you of the action taken. We may also decline to act on the request.

13.12 If we have doubts about the identity of the person submitting a request, we may ask that individual to provide reasonable verification of their identity.