Firm Vestode

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: 21.08.2026

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 Firm Vestode (the "Website").

We want you to be able to make informed decisions about how your Personal Data is used and processed. We use a range of methods to ensure you receive relevant information, and where specific details are required, we will provide them at the appropriate time. We are happy to address any questions you have regarding limitations imposed by law.

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

1. The Scope

1.1 This policy sets out the types of Personal Data the Company collects about natural individuals, and how that data is processed, shared with third parties, and kept secure.

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 designed for anyone under the age of 18. We do not knowingly collect information from individuals younger than 18, nor do we knowingly permit them to use our services. Should we become aware that we hold information relating to a child, we will delete it promptly.

2. What Personal Data Do We Have on You

2.1 When you access our services and channels or visit our website, we collect personal data. In certain circumstances, we may also request personal data directly from you.

2.2 In other cases, we 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 data 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 to a third-party online trading platform through us.

4.4 Personal information you provide directly 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 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:

  • You have consented to the processing of your personal data for one or more specified purposes. This applies where you submit personal data via the Website so that it can be passed to a third-party trading platform.
  • In some cases, we or a third party may need to process your data to pursue a legitimate interest — such as improving our Services or defending legal claims.
  • Processing must meet an obligation of law.

For further details on the processing carried out to protect legitimate interests, please 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:

Scope

Legal Basis

Where you request it, we may collect your personal data and share it with third-party companies to facilitate 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
We use your personal data to address any questions you may have about our Services.

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

Personal data is processed to meet applicable legal, administrative, and judicial obligations.

To ensure compliance with legal obligations, processing is required.

4. To Improve Our Services
We may use personal data to improve our Services. This includes crash reports and malfunction data collected in connection with the Services.

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

5. To stop fraud and misuse of Our Services.

Processing is necessary to serve the legitimate interests of the Company or a third party.

6. To carry out and manage activities required to operate Our Services
This includes back-office functions, business development, strategic decision-making, and oversight.

Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.

7. To conduct analysis, such as statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas of our operations.

Processing is necessary to pursue the legitimate interests of the Company or a third party.

8. To protect our assets, rights, and interests, and 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 relevant conditions, terms, or policies.

Processing is 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 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 will then be subject to their respective privacy policies. Please be aware 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 where doing so supports the development 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 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 such as a transfer or sale of assets, merger, restructuring, consolidation, or insolvency affecting the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may work with third parties — such as advertisers and analytics providers — who operate on our website and may use cookies or similar 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 most relevant to you. Cookies are also used for statistical and analytics purposes.

Some cookies used on this Website are session cookies. These are temporarily downloaded to your device and 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 recognise you as a returning user and help you resume your session.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary to access the features you've requested and to navigate our website. They enable us to deliver the information, products, and services you've asked for, and allow your device to download and stream data. This lets you move around the site, use its features, and return to pages you've previously visited.

Additional Information

Session cookies collect personal data such as your username and last login date to verify you are logged in. They are deleted automatically when you close your browser.

The type of cookie

Functionality Cookies

Scope

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

Additional Information

They remain active until their expiry date and persist even after the browser is closed.

The type of cookie

Cookies for performance

Scope

We use cookies to collect statistical data about site performance and to carry out analysis that helps us improve your experience.

Additional Information

Cookies store anonymous data that is not associated with any identified or identifiable individual. Some cookies are deleted when you close your browser; others remain valid indefinitely.

7.4 If you want to block or remove cookies, you'll need to adjust your browser settings. The links below walk you through the process for some of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please note that disabling certain Website functions may cause some or all features 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 permitted by applicable law, regulation, or regulatory order.

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.

8.3 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 the personal data you provide and to ensure that you retain the ability to exercise your rights and access effective legal remedies.

These protections and safeguards apply to all individuals residing in the EEA (European Economic Area):

  • Transfers to a third country or international organisation where the European Commission has determined, under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR"), that an adequate level of protection for Personal Data is ensured.
  • This transfer is made under a legally binding and enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
  • The transfer was made in accordance with standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.

9.3 The Company can provide details about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, email: support@firmvestode.com

10. Security of Personal Data

We have implemented appropriate organisational 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 accept liability 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 reasonable control.

10.3 Where legal or other obligations beyond our control require it, we may need to disclose your Personal Data to third parties, such as 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 completely 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 may contain links to third-party sites and applications that are not under the Company's supervision. We are not responsible for the collection or processing of personal data by those sites or applications. This Policy does not apply to any actions taken through them.

When visiting any third-party websites or apps, we recommend reading their privacy policies before accessing or using their services. You should also exercise caution when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. Any changes will be communicated by publishing the revised Policy 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 otherwise specified, 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 Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope or type 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 in relation to your personal data. To exercise any of these rights, please contact us at the email address below.

13.3 Access rights You have the right to verify whether the Company is processing Personal Data about you, and if so, 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 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 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 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 based on legitimate interests pursued by Us or a third party; (e) the Personal Data are unlawfully processed; or (f) erasure is required 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 law or Member State law; or (b) to establish, exercise, or defend legal claims.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to 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 individual, or where there is a substantial public interest 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 on 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 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 your Personal Data where that processing is based on legitimate interests pursued by the Company or a third party. This right is not limited to 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 claims, we may continue to process your Personal Data. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.

13.9 Right to withdraw 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 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 its member states may limit your rights in relation to your Personal Data, as set out in this section 13.

We will respond to requests made under the rights set out in section 13 of this agreement within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.

Subject to section 13 of the law, any information provided in response to a request made under your section 13 rights will be supplied free of charge. Where a request is unfounded or excessive — in particular where requests are repetitive — we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may decline to act.

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

Please read this Privacy Policy alongside our Term Of Use and Risk Disclosure.

Firm Vestode 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@firmvestode.com