Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, 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 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 available to anyone under the age of 18. We do not knowingly collect information from or permit use of our services by minors. If we become aware that we hold data relating to a person under 18, 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 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 our 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

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 voluntarily provide to us when connecting with a third-party online trading platform through us.

4.4 Personal information you share directly with 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 on how we process data to protect legitimate interests, contact us by email.

5.4 The following sets out the purposes and legal grounds on which we may use the information you provide to us:

6. Transfer of Personal Data to Third Party

The Company may also share personal data with third-party service providers that support our operations, including hosting and storage providers, IP address processors, and user experience analytics services.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us to those platforms. Your Personal Data will then be governed by their respective privacy policies. Please note that your Personal Data may be shared with more than one third-party 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 or assets of third parties, 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 company within the group, in connection with a transaction involving the transfer or sale of Company assets, a merger, restructuring, consolidation, or bankruptcy of the Company or any other entity 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 behavior to improve your experience, remember your settings, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.

Some cookies we use 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. Persistent cookies allow the Website to recognize you as a returning user and help restore your access on subsequent visits.

7.5 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 fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for a period of 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 organizations. The Company takes all necessary steps to protect your personal data and ensure you retain the ability 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@rillforgecapital.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, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.

In some cases, we may be legally or otherwise required to disclose your Personal Data to third parties, including public authorities. In such situations, 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 completely secure. The Company cannot ensure the security of any personal data you send to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 This 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 applications collect or process personal data. This Policy does not apply to any actions taken through third-party sites or applications.

11.2 When visiting any third-party websites or apps, read their privacy policies before accessing or using 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 revised Policy 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 that we verify the accuracy of the personal data we hold about you, correct any errors, and delete any personal data we no longer require. You may also restrict the scope or types of processing applied to your personal data.

If you are a resident of the EEA, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, submit a request by emailing the 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 to access 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 can fulfil it.

13.4 Right to rectification The Company may correct any inaccurate Personal Data it holds about you. You have the right to request that incomplete Personal Data relating to you be rectified, having regard to the purpose of processing.

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 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 reason 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 from the Company to another controller, where technically feasible. Exercising this right 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 extends beyond profiling based solely on those interests. Where we can demonstrate compelling legitimate grounds for 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 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 refuse consent You may withdraw your consent for Us processing Personal Data about you at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your relevant supervisory authority. Within the European Union, you may submit a complaint to 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 EU and member state laws 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 additional months, depending on the complexity or volume of requests received. You will be notified of any extension, along with the reasons, within one month of your original request.

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 the action taken. We may also decline to act on such requests.

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