Privacy Policy
Last updated: 12/04/2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website https://keen-ledmere.com (the Keen Ledmere ).
These principles will be upheld:
To ensure transparency in how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we have created our website. To support this, we use different methods and procedures to provide you with relevant information about the use of Personal Data.
If we believe you need specific details, we will provide that information at the appropriate date and time.
We are happy to answer any questions you may have and provide any clarification you require regarding any limitations imposed by law. You can reach us by email at the address below: info@keen-ledmere.com
Personal Data will be used only for the purposes specified in the Policy.
We may process Personal Data for various purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with regulatory or legal obligations, and carrying out administrative and business activities to support the delivery and use of the Services.
Personal Data is also processed by us to better understand your preferences and needs.
To use key tools to protect your rights regarding Personal Data:
To support the exercise of your rights, we have dedicated substantial resources. Contact Us anytime to request Personal Data about your personal data. We will modify or delete it, stop using it for specific or general purposes, and transfer the information to you or to an outside party. We will do our best to accommodate your requests.
Protect your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to use a range of methods and techniques to help protect your Personal Data.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data Keen Ledmere collects from natural persons and how it processes, shares with third parties, secures, and otherwise handles that data.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or by combining additional information that we have or can access.
The Policy defines "processing" as a process that involves the use or collection of Personal Data. It includes the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old. We do not knowingly allow such persons to use our services. We will erase any information we discover about children as quickly as possible if we become aware of it.
2. What Personal Data Do We Have on You?
When you access our services and channels or visit our website, we collect Personal Data. In some cases, we may ask for your Personal Data. In other cases, we collect your Personal Data by analysing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. There is no requirement to disclose personal information to the company or face any consequences.
However, you are not required to provide Us with any personal Data. In certain circumstances, however, you may not need to provide Us with any Personal Data. This may prevent Us from offering the Services or prevent users from accessing the website.
4. What Personal Data can We collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including IP address, the date of access, the time of access, and the date of access), the language used, software crash logs, the type of browser used, as well as information about the device you utilized. The information collected is not private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide to Us when you connect with a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.
5. The legal basis and reasons for processing Personal Data
Your Personal Data is processed by the Company for the purposes described in this section, and in line with the applicable legal basis.
Without a legal basis, the Company is unable to use your Personal Data. The legal grounds on which the Company may process your Personal Data:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to meet their legitimate interests. For example, this may be necessary to improve Our Services or defend legal claims.
- Processing must comply with a legal obligation.
Contact Us by email for further details on the processing required to protect legitimate interests.
Below is a list of reasons and legal bases for which we may use the information you provide to us. Personal Data.
Scope, Legal Basis
1. To provide your personal information to third parties at your request to access digital trading. If you request this, we may collect Personal Data from you to forward to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions, or concerns. Personal Data is required to help address any questions you may have about the Services.
The Company’s legitimate interests or those of a third party need to be processed.
3. To meet any legal, administrative, judicial or other legal obligations, Personal Data is processed to comply with legal requirements.
Processing is required to ensure compliance with legal obligations.
4. To improve Our Services, we may use Personal Data. This includes, among other things, crash or malfunction reports we collect in connection with the Services.
The legitimate interests of the Company or those of a third party need to be processed.
5. To prevent fraud and misuse of Our Services
The Company’s legitimate interests or the interests of a third party need to be processed.
6. To carry out and manage activities in accordance with the requirements of Our Services. These activities include back-office functions, business development initiatives, strategic decision-making, oversight mechanisms, etc.
The Company's legitimate interests or those of a third party need to be processed.
7. To carry out analysis, including statistical analysis. We use different analytical techniques (including statistical methods) to make decisions on different issues.
The legitimate interests of the Company or those of a third party require processing.
8.
To safeguard our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
The Company’s legitimate interests or those of a third party need to be processed.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party service providers that support us, such as hosting and storage providers, IP address information services, and user experience analytics.
You may also request that we provide specific Personal Data relating to you to third-party trading platforms. In such cases, we will share the Personal Data you provide to Us with those third-party trading platforms. The use of your Personal Data will then be subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners. This may provide the Company with the resources it needs to enhance and improve the products and services it offers to its customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company in the group if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Third-party cookies and services
Third-party services, such as those providing advertisements on our website or analytics companies, may be utilized. These companies may also utilize cookies or other technology.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and personalize the products and services you may enjoy. Cookies are also utilized for statistics and analytics.
Certain cookies we may make use of are session cookies. They are temporarily downloaded to your device and remain for a short period before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are utilized to help the Website identify you as a returning user and enable you to return to the website.
Types of Cookies:
They may be used by us depending on their purpose:
1. Cookies are essential
These cookies are necessary to let you access the features you have requested and navigate our website. Cookies are used to deliver the information, products and services you have asked for.
They are required for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you have previously visited.
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
2. Functionality Cookies
Cookies allow us to recognize you each time you visit our site and also save your preferences and settings.
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
3. Cookies for performance
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow Us to conduct analysis on our website.
Cookies store anonymous data that is not associated with any identified or identifiable natural person. They can be removed when you close your browser. Other cookies have indefinite validity.
Cookies are blocked or have been removed
To allow or delete cookies, you need to change your browser settings. Below are links to guide you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all of the Website's functions and features may not work as you expect if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfill the purpose of processing it, as described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue to share your data for another 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfer of personal information to a third-party country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country (i.e. a country other than the one in which you reside) or to international organizations. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data subjects are able to exercise their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. (the "GDPR")
- The transfer is carried out pursuant to a legally binding, enforceable agreement between public entities or authorities within the viro Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses, as adopted by the EU Commission, can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information on the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Send an email to the following address at info@keen-ledmere.com
10. Personal Data Security
We have taken appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will always be maintained without error. We also cannot be held responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
In the event of legal obligations or other obligations beyond our control, we may be required to provide Personal Data relating to you to third parties, such as public authorities. We cannot control the level of security provided to your Personal Data by third parties in these situations.
Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Links to third-party websites
Links to third-party sites and applications are available on the website. These sites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to any actions taken through such sites or apps.
When you visit any third-party website or app, We recommend that you read their privacy policies before deciding to access or use their apps. We also suggest that you provide any Personal Data to them.
12. Changes to this Policy
When you visit any third-party websites or apps, We recommend reading their privacy policies before deciding whether to access or use their apps. We also suggest that you provide any Personal Data to them.
13. Your rights regarding your personal information
You have the right to ask us to verify the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data that is no longer required by Us. You may also restrict certain types of processing of personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you in relation to the information you provide as part of your Personal Data. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company may verify whether Personal Data relating to you is being processed. If it is, you are entitled to access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request adversely affects the rights and freedoms of another person or their rights, the Company may refuse to comply with the request or limit its ability to fulfill it.
Right to rectification
The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.
Right to Erasure
The following reasons apply: (a) Personal Data is no longer required for the purpose for which it was collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, for reasons specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued either by Us or by a third party; (e) Personal Data is processed unlawfully or f) Personal Data must be deleted to comply with the legal obligations of the company.
This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or Member State law; or (b), to establish, exercise or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data.
If you request that Personal Data be restricted, it may only be stored with your consent or for the purpose of establishing, exercising or defending legal rights, or protecting the rights of another natural person, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
If the processing is carried out by automated means and is based on consent or a contract to which you are a party, you have the legal right to review your Personal Data that you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right of erasure are not affected by the exercise of your right to data portability. The right to data portability does not affect the rights or freedoms of others.
Right to challenge
You have the right at any time to object to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we are able to demonstrate compelling legitimate grounds for processing Personal Data, we may continue processing unless you show that your rights, freedoms, or interests override those grounds, or where the processing is for the establishment, exercise or defense of legal rights.
In relation to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to refuse consent
You may withdraw your consent to Our processing of your Personal Data at any time. This will not affect the legality or lawfulness of any processing carried out based on your consent before it was withdrawn.
You are entitled to lodge a complaint with the supervisory authority responsible for you.
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 within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide you with the information requested under the rights set out in section 13 of this agreement within a month of receiving your request. This period may be extended by up to two months if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Provided this does not conflict with section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.
If we have doubts about the identity of the person who submitted your request, the Company may ask for additional information.