Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about individuals, and 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 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 available to anyone under the age of 18. We do not knowingly collect information from or permit use of our services by persons under 18. Any such information we become aware of will be deleted 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 specific personal data from you.

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 information and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when you connect 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.

For more information about how we process data to protect legitimate interests, 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:

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 platforms 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 these instances 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 its customers.

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

We may also share your Personal Data with potential investors or buyers, lenders to the Company, or any other company within the group in connection with a transaction — including the transfer or sale of Company assets, a merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

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

7.3 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 and are used to recognise you as a returning user and restore your access to the Website.

Please note that disabling certain features may cause some or all Website functions to behave unexpectedly.

Online Tracking Notice: This service does not currently respond to 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 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 this, 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 to international organisations. 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@keentillwardance.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 error. We also accept no liability 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 Where legal or other obligations outside our control require it, we may be required to disclose your Personal Data to third parties, including public authorities. In such cases, we have no control over how those third parties protect your Personal Data.

10.4 Transmitting personal data over the internet carries inherent security risks. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through such sites or applications.

Before accessing or using any third-party websites or apps we recommend, read their privacy policies carefully. Only share your personal data with them once you are satisfied with how it will be handled.

12. Modifications to This Policy

This Policy may be updated at any time. When changes are made, the updated Policy will be posted 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 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 Personal Data collected about you, to have any inaccuracies corrected, and to request deletion of Personal Data we no longer require. You may also restrict the types of processing applied to your Personal Data.

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, send a request to the email address below.

13.3 Access rights The Company can verify the accuracy of Personal Data being processed about you. Where this is 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 it, the data will be provided in electronic form. The right to access Personal Data must not infringe on the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse to comply or limit the extent to which it fulfils the request.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You may also request the rectification of incomplete Personal Data, 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 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, 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 have been unlawfully processed; or (f) the Personal Data must be erased to comply with 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. 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 a significant public interest within the European Union or a Member State applies.

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 does not override 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, including profiling based on those interests. Where we 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 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 Withdraw Consent You may withdraw your consent for Us to process your Personal Data at any time. Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal. You are also entitled to lodge a complaint with your supervisory authority. Within the European Union, you may file 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 European Union and Member State laws may limit the rights described in this section 13.

We will respond to your request within one month of receiving it, in accordance with the rights set out in section 13 of this agreement. Where necessary, this period may be extended by up to two months, depending on the nature and volume of requests received. If an extension is required, we will notify you within one month of receiving your request and explain the reason for the delay.

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 fulfilling the request or notifying you of any action taken. 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 require that person to provide appropriate verification of their identity.