Keen Comptalorine

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

Last updated: 08.10.2026

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 Keen Comptalorine (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 informed and will provide specific details when relevant and timely. We are also happy to address any questions you have regarding applicable legal limitations.

By using our website, you confirm that you have read and agree to this Privacy Policy. For questions, contact us at support@keencomptalorine.com

1. The Scope

1.1 This policy explains what Personal Data the Company collects about natural individuals, and how that data is processed, shared with third parties, and secured.

1.2 This Policy applies to information relating to an identified or identifiable natural person. A natural person is considered identifiable if they can be identified 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 any 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 ask you to provide personal data directly.

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 granting you access to the website.

4. What Personal Data We Collect

4.1 This includes your online activity log and traffic data such as:

  • 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 you provide to us at your own discretion when connecting to 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 set out in this section, in accordance with the applicable legal basis.

5.2 The Company may only process your Personal Data 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 this 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 pursue legitimate interests — such as improving our Services or defending legal claims.
  • Processing must meet an obligation of law.

For more information on the processing carried out to safeguard legitimate interests, please contact us by email.

5.4 The following outlines the purposes and legal bases on which we may use the information you provide to us:

Scope

Legal Basis

If requested, we may collect your personal data to share with third-party companies in order to facilitate your 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 have about the Services.

Processing data is necessary to serve the legitimate interests of the Company or a relevant 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 Enhance Our Services
We may use personal data to improve Our Services, including crash reports and malfunction data collected in connection with the Services.

Processing is required to support the legitimate interests of the Company or a third party.

5. To stop fraud and misuse of Our Services.

Processing is required 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 functions, business development, strategic decision-making, and oversight activities.

Processing personal data may be necessary to serve the legitimate interests of the Company or a third party.

7. To conduct statistical and other analysis
We use a range of analytical techniques, including statistical methods, to support decision-making across different areas of our operations.

Processing is required to support the legitimate interests of the Company or a third party.

8. To safeguard our assets, rights and interests 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 accordance with applicable laws, regulations, agreements, and any related conditions, terms, or policies.

Processing personal data may be necessary to serve the legitimate interests of the Company or a 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, as well as companies that analyse user experience and IP address data.

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 relevant Personal Data to those platforms as requested. Your Personal Data will then be subject to the privacy policies of the respective third-party 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 support the enhancement and improvement of the products and services provided to customers.

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 share your Personal Data with potential investors, buyers, or lenders to the Company or any group company in connection with a transaction involving the transfer or sale of assets, or as part of a 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, 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 tailor the products and services most relevant to you. Cookies are also used for statistics and analytics purposes.

We use two types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognise you as a returning user, allowing the Website to restore your previous session.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are required to give you access to the features you've requested and to enable navigation across our website. They allow your device to download and stream data, so you can browse pages, use site features, and return to previously visited sections.

Additional Information

Cookies collect personal data — such as your username and last login date — to verify that you're logged in. They are deleted automatically when you close your browser (session cookies).

The type of cookie

Functionality Cookies

Scope

Cookies recognise you each time you visit our site and save your preferences.

Additional Information

These cookies persist until their expiry date and remain stored even after the browser is closed.

The type of cookie

Cookies for performance

Scope

We use cookies to collect performance data and analyse how our website is used, helping us improve the overall experience.

Additional Information

Cookies store anonymous data that is not linked to any identifiable individual. 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 can guide you through the process for some of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

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

Online Tracking Notice: This service does not currently support 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 required or permitted by applicable law, regulation, or order.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this 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.

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 European 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 pursuant to Article 46(2)(a).
  • This transfer was carried out in accordance with the 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@keencomptalorine.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 without error, nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.

Under certain legal or regulatory obligations beyond our control, 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 handle or protect your Personal Data.

10.4 Transmitting personal data over the internet cannot be guaranteed to be fully secure. The Company cannot ensure 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 that are not under the Company's supervision. We are not responsible for how those sites or apps collect or process Personal Data. This Policy does not apply to actions taken through third-party sites or applications.

Before visiting any third-party website or app, read their privacy policy carefully before deciding to access or use their services. Exercise caution when sharing any personal data with 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, amendments take effect upon publication of the revised Policy.

13. Your Rights

You may request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete 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 regarding 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, where it is, to access that data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. This right must not infringe on 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 response accordingly.

13.4 Right to rectification We may correct any inaccurate Personal Data we hold about you. You may also request that incomplete Personal Data be rectified, 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, on grounds relating to your particular situation, to 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) erasure is required 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 such a restriction is requested, 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 significant public interest ground 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 your right to data portability does not affect your right to erasure. The exercise of this right must not adversely affect the rights or freedoms of others.

13.8 Right to challenge You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those 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 rights, we may continue to do so. 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 processing Personal Data about you at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of consent prior to its withdrawal. You have the right to lodge a complaint with a relevant supervisory authority. Within the European Union, you may contact the supervisory authority established by the applicable member state to protect individuals' fundamental rights in relation to the processing of Personal Data. Please note that EU law and the laws of individual member states may limit the rights set out in this section 13.

We will respond to your request for information 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 and volume of requests received. You will be notified of any extension, along with the reasons for it, within one month of your original request.

Subject to Section 13 of the law, information requested under your Section 13 rights will be provided at no cost. Where a request is unjustified or excessive — particularly where requests are repeated — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

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.

Keen Comptalorine 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@keencomptalorine.com