Privacy Policy

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 https://greyvaultholm.com (the Grey Vaultholm).
The following principles apply:

We want you to be fully informed about how your Personal Data is used and processed. We use a range of methods to keep you appropriately informed, and where specific details are needed, we will provide them at the relevant time. We are happy to address any questions you may have regarding applicable legal limitations.

1. The Scope?

This policy describes the types of personal data Grey Vaultholm collects about natural persons, and how that data is processed, shared with third parties, and secured.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of information we hold or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its management, structuring, and storage.
Our services are intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18, and we do not permit such persons to use our services. If we become aware that personal data has been collected from a minor, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our Services, service channels, or website, we collect Personal Data. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our Services or via information received from our third-party partners.

3. You are not required to share personal information with the company. However, withholding it may affect the services available to you.

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering our Services or granting you access to the website.

4. What personal data do we collect? When you visit our website, we may collect the following personal data:

This includes information about your online activity log, traffic data (such as IP address, access dates and times), language preferences, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data we receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal information provided to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Scope, Legal Basis

6. Sharing Personal Data with Third Parties We may share your personal data with third parties in the following circumstances: With your consent. We share personal data with third parties when you have given us explicit permission to do so. Service providers. We engage trusted third-party service providers to operate and support our Services on our behalf. These providers are granted access to your personal data only to the extent necessary to perform their functions and are contractually required to keep it confidential. Legal obligations. We may disclose personal data where required by law, regulation, or a binding order from a competent authority. Business transfers. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party. We will notify you before your personal data becomes subject to a different privacy policy. Protection of rights. We may disclose personal data when we reasonably believe it is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request. We do not sell, trade, or rent your personal data to third parties for marketing purposes. Any third party receiving your personal data is required to handle it in accordance with applicable data protection standards and this Privacy Policy.

The Company may also share Personal Data with third-party service providers — such as hosting and storage providers — for purposes including IP address processing and user experience analysis.
You may request that we share specific Personal Data about you with third-party trading platforms. Where such a request is made, we will provide the relevant Personal Data to those platforms accordingly. Your Personal Data shared in this way is governed by the privacy policies of those third-party trading platforms. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners where doing so supports the development and improvement of products and services offered to customers.
Where necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
The Company may also share Personal Data with prospective investors, buyers, or lenders — whether relating to the Company or any other entity within the group — in connection with a transaction, including the transfer or sale of assets, or as part of any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other entity within the group.

7. Third-Party Cookies and Services

We may work with third-party service providers, including advertising partners and analytics companies, who may also use cookies or similar technologies on our website.
Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences, improve your experience, and tailor the products and services presented to you. Cookies are also used for statistical and analytics purposes.
There are two types of cookies we may use. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and help the website recognise you as a returning user, allowing you to resume your experience seamlessly.

Types of Cookies:

We may use them based on their purpose:

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

8. How We Retain Your Personal Data

We 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.
We share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue sharing your data for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Data to a Third Country or International Organisation

10. Protecting Your Personal Data We take the security of your personal data seriously and implement appropriate technical and organisational measures to safeguard it against unauthorised access, accidental loss, alteration, or disclosure. No method of transmission over the internet or electronic storage is completely secure. While we work to protect your personal data using commercially reasonable means, we cannot guarantee absolute security. You acknowledge and accept this inherent risk when providing us with your personal data. Access to your personal data is restricted to personnel and authorised third parties who require it to perform their functions. All such parties are subject to confidentiality obligations. In the event of a personal data breach that poses a risk to your rights and freedoms, we will take appropriate steps in accordance with our obligations, including notifying the relevant authorities and, where required, the affected individuals. You are responsible for keeping any account credentials confidential. Do not share your login details with anyone. If you suspect unauthorised access to your account, notify us immediately. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Once no longer needed, your personal data will be securely deleted or anonymised.

We have implemented appropriate organisational and technical measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your personal data will be maintained 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.
Where legal or other obligations require it, we may be required to disclose personal data to third parties, including public authorities. In such cases, we have no control over the security measures applied to your personal data by those third parties.
Transmitting personal data over the internet carries inherent risk. We cannot guarantee the security of personal data you send to us through the internet.

11. Links to Third-Party Websites

Our website contains links to third-party websites and applications. These sites and apps 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 them.
Before accessing or using any third-party website or app, we recommend reading its privacy policy carefully. We also advise exercising caution before providing any personal data to such sites or apps.

12. Changes to this Policy We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, we will notify you directly. We encourage you to review this Policy periodically to stay informed of any updates.

Before accessing or using any third-party websites or apps, read their privacy policies carefully. Only share personal data with them once you are satisfied with how they handle it.

13. Your rights regarding your personal information

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. 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:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
The Company can verify that your Personal Data is being processed. If it is, you may 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. Data will be provided in electronic format upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may decline or limit its response.
Right to rectification
The Company will correct inaccurate Personal Data. You may also request that incomplete Personal Data be completed, taking into account the purpose of processing.
Right to erasure
This right applies where: (a) Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party, based on grounds specific to your situation; (e) Personal Data is unlawfully processed; or (f) Personal Data must be deleted 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 or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you question the accuracy of your Personal Data, you may request that the Company restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, for the establishment, exercise, or defense of legal claims, for the protection of another person's rights, or where there is a substantial public interest within the European Union or a Member State.
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 the Personal Data you have provided to the Company in a structured format.
You may request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure, nor does it affect the rights or freedoms of others.
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 solely on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defense of legal claims, we will cease processing.
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to the processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may lodge 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 within the European Union.
European Union and Member State law may limit the rights described in this section 13 as they relate to your Personal Data.
We will respond to requests made under section 13 within one month of receipt. Where necessary, depending on the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any such extension within one month of receiving your request, along with the reasons for the delay.
Subject to the provisions of section 13, information provided in response to your requests will be supplied free of charge. Where requests are unfounded or excessive, in particular where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt as to the identity of the person submitting a request, we may ask for additional information to confirm identity.