Privacy Policy
Last update: 13/06/2026
We (also known as "We", "Us" or "Our") are committed to protecting your personal data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://pale-kestmark.com (the Pale Kestmark ).
We uphold the following principles:
To be transparent about how we process and collect your personal information:
We want to ensure you can make informed decisions about how your Personal Data is used and processed. That's why we've created this website. We use a variety of methods and procedures to keep you informed about our data practices.
If we believe you need specific details, we'll provide them to you at the appropriate time.
We're happy to answer any questions and provide clarification on any legal limitations that may apply. You can contact us via email at: info@pale-kestmark.com
Your personal data will only be used for the purposes outlined in the Policy.
Personal Data may be processed by us for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and conducting administrative and business activities. We also process Personal Data to better understand your preferences and needs.
Personal Data are also processed by us in order to better comprehend your preferences and needs.
To make use of significant tools to protect your rights with respect to Personal Data:
To help you exercise your rights, we have substantial resources available. Contact us at any time to request information about your personal data. We can modify or delete it, cease using it for specific or general purposes, or transfer it to you or a third party. We're committed to accommodating your requests promptly.
Secure Your Personal Data
Whilst we cannot guarantee complete security of your personal data, we can assure you that we continuously employ a range of methods and techniques to safeguard it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy outlines the types of personal data Pale Kestmark collects from individuals and how it processes, shares, and protects that information.
This policy applies to information relating to an identified or identifiable natural person. An identifiable person is someone who can be directly identified or recognised through a combination of information we hold or can access.
The policy defines "processing" as any activity involving the use or collection of personal data, including its management, organisation, and storage.
Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect or solicit information from anyone younger than 18, nor do we permit such persons to use our services. Should we become aware of any information collected from children, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you access our service and channels or visit our website, we collect Personal Data about you. We may ask for your Personal Data directly in certain cases, or we may gather it by analysing your use of our Services and channels, or by receiving information from our third-party partners.
3. You are not required to disclose personal information to the company, and there are no consequences for doing so.
However, you're not required to provide us with any personal data. In certain circumstances, if you choose not to supply personal data, we may be unable to offer our services or allow access to the website.
4. What Personal Data Do We Collect? When you visit our website, we gather the following personal information:
This includes information about your online activity log, traffic data (such as IP address, access date, access time, and browser type), the language you used, software crash logs, and details about your device. The information collected is not personally identifiable and cannot be used to identify you.
Personal Data We Receive From You: any personal information you choose to provide when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms: this information includes your full name, address, phone number, and email address to facilitate trading activity.
5. The Legal Basis and Reasons for Processing Your Personal Data
Your Personal Data is processed by the company for the purposes outlined in this section, and in accordance with the applicable legal basis.
Without a legal basis, the company cannot process your Personal Data. The legal grounds on which the company may process your Personal Data are as follows:
- You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- We or a third party may need to process your data to serve our legitimate interests. For example, this might include improving our services or defending legal claims.
- Processing must comply with legal requirements.
Contact us via email for further information regarding the processing required to protect our legitimate interests.
Below is a list of the reasons and legal grounds we may use when processing your personal data.
Scope, Legal Basis
1. We may request your personal information to share with third-party companies if you ask us to, so you can access digital trading services. Your data will only be forwarded with your consent.
You have consented to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions, or concerns, we collect Personal Data to help answer any questions you may have about our Services.
The Company or a third party may need to process your information to pursue legitimate interests.
3. We process your Personal Data to comply with legal obligations and to meet administrative, judicial, or regulatory requirements.
To meet our legal obligations, we must process your information.
4. To improve our services, we may use your personal data. This includes collecting reports on any crashes or malfunctions related to the services we provide.
We need to process personal data to protect the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
The Company or a third party has a legitimate interest that requires the processing of your data.
6. To carry out and oversee actions that align with the requirements of Our Services, including back-office operations, business development activities, strategic decision-making, and compliance oversight.
We need to process your data to protect the legitimate interests of the Company or a third party.
7. To conduct analysis—such as statistical analysis—and inform decision-making on various matters, we employ a range of analytical techniques, including statistical methods.
We need to process personal data to pursue the legitimate interests of the Company or a third party.
8. To protect our assets, rights and interests, as well as those of third parties, we process personal data in accordance with applicable laws, regulations and agreements. This includes establishing and defending legal claims where necessary. Your data may be processed to safeguard our rights, interests and assets, or those of other parties, in compliance with all relevant terms, conditions and policies.
The Company or a third party's legitimate interests require the processing of your data.
6. Transferring Your Personal Data to Third Parties
The Company may share your Personal Data with third-party service providers such as hosting, storage, and analytics providers to support our operations and improve your user experience.
You can request that we share your Personal Data with third-party trading platforms. When you do so, we will provide your Personal Data to these platforms in accordance with their respective privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.
We may also share Personal Data with affiliated entities or business partners to help us enhance and improve the products and services we offer.
The Company may disclose Personal Data to regulatory authorities, local authorities, or other official bodies where necessary to protect the rights of third parties or safeguard assets.
Additionally, we may share Personal Data about you with prospective investors, buyers, lenders to the Company, or other entities within our group of companies in connection with any proposed transaction (including the transfer or sale of Company assets or assets of any group company), merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other group entity.
7. Third-party cookies and services
Third-party services, such as advertising and analytics providers, may be used on our website. These companies may also use cookies or similar technologies.
Cookies are small text files that are stored on your device each time you visit or use the website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your settings, and personalise the products and services we think you'll enjoy. Cookies also help us with statistics and analytics.
Some cookies we use are session cookies. These are temporary files downloaded to your device and expire when you close your browser. Other cookies are persistent cookies, which remain on your device for a period of time after you close your browser. We use these to recognise you as a returning user and allow you to return to the website more easily.
Types of Cookies:
They may be used by us according to their intended purpose:
1. Cookies are essential
These cookies are essential for accessing the features and services you've requested and for navigating our website. They enable your device to download and stream data, allowing you to move through the site, use its features, and return to pages you've previously visited.
Without these necessary cookies, the website cannot function properly or deliver the content and services you've asked for.
Cookies collect personal data, such as your username and last login date, to confirm you're logged in to the site. They're automatically deleted when you close your web browser (session cookies).
2. Functionality Cookies
Cookies allow us to recognise you when you visit our site and help us save your preferences each time.
Cookies collect personal data, such as your username and last login date, to confirm that you're logged in to the site. They're automatically deleted once you close your web browser (session cookies).
3. Cookies for performance
We use cookies to gather statistical data on site performance and enhance your experience. They also allow us to analyse how our website is being used.
Cookies store anonymous data that isn't linked to any identifiable individual. Some cookies are automatically removed when you close your browser, whilst others remain indefinitely.
Cookies are blocked, or removed
To prevent or remove cookies, you'll need to adjust your browser settings. Below are links to help guide you through the process for some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Be aware that certain features or the entire website may not function as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. The retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer periods as permitted by applicable law, regulations, and orders.
We'll 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 regularly review the Personal Data we hold to ensure it's no longer required.
9. Transfer of Personal Information to Third Countries or International Organisations
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third-country or to international organisations). The Company takes all necessary steps to safeguard your personal data and ensure that data subjects can assert their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has deemed to provide adequate protection of Personal Data, as determined under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with the standard contractual clauses approved by the EU Commission under Article 46(2)(c) of the GDPR. You can view the clauses approved by the EU Commission 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 details about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please send an email to info@pale-kestmark.com to request this information.
10. Security of Your Personal Data
We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration. We cannot guarantee that Personal Data will remain secure in all circumstances. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data, including those arising from transmission errors, unauthorised third-party access, or other causes beyond our control. Where required by law or other obligations beyond our control, we may be obliged to share Personal Data about you with third parties, such as public authorities. In these situations, we cannot be responsible for the security measures those third parties apply to your Personal Data. Data transmission over the internet cannot be entirely secure. The Company cannot guarantee the security of Personal Data you send to us online.
11. Links to external websites
The website contains links to third-party websites and applications that operate independently of the Company. We are not responsible for how these sites or apps collect or process your Personal Data. This Policy does not apply to activities conducted through such third-party platforms.
Before accessing or using any third-party website or application, we recommend that you review their privacy policies. We also advise you to exercise caution when sharing any Personal Data with them.
12. Changes to this Policy
Before accessing any third-party websites or apps we recommend, we encourage you to review their privacy policies first. We also suggest exercising caution when sharing any personal data with them.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of your Personal Data, rectify any errors, and delete all Personal Data that is no longer necessary. You may also restrict how your personal information is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide regarding your Personal Data. You may exercise these rights by sending an email to the address below.
Access rights
The Company can verify the accuracy of your Personal Data and confirm whether it is being processed. If so, you have the right to access your Personal Data.
The Company will provide an electronic copy of your Personal Data at no charge. Additional copies may be subject to a reasonable fee. The data will be made available electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If a request would harm another person's rights or freedoms, the Company may refuse the request or limit its response.
Right to rectification
You are entitled to have inaccurate or incomplete Personal Data corrected, taking into account the purpose for which it is being processed.
Right to erasure
You may request erasure in the following circumstances: (a) 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, for reasons specific to your situation, to processing based on legitimate interests pursued by us or a third party; (d) Personal Data are being processed unlawfully; or (e) Personal Data must be deleted to comply with a legal obligation.
This right does not apply if processing is necessary (a) to fulfil an obligation required by European Union or Member State law, or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
If you request that Personal Data be restricted, it may only be retained with your consent, or to establish, exercise or defend legal rights, or to protect the rights of another individual, or where there is a significant public interest within the European Union or a Member State.
Right to data portability
If processing is carried out by automated means and is based on your consent or a contract you are party to, you have the right to access your Personal Data in a portable format.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your right to erasure is not affected by exercising your right to data portability. The right to data portability does not prejudice the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of your Personal Data based on legitimate interests pursued by the Company or a third party. This includes processing for profiling purposes based on legitimate interests. If we can demonstrate compelling legitimate grounds for processing that outweigh your rights, freedoms or interests, or if processing is necessary to establish, exercise or defend legal rights, we may continue processing.
Regarding direct marketing, you have the right to object to processing of your Personal Data at any time.
Right to withdraw consent
You may withdraw your consent for the Company to process your Personal Data at any time. This does not affect the lawfulness of processing that was carried out before your withdrawal.
You are entitled to lodge a complaint with the supervisory authority in your jurisdiction.
You may lodge a complaint with a supervisory authority in any Member State to protect your fundamental rights regarding the processing of your Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights regarding your Personal Data, as detailed in this section 13.
We will provide the information you request under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests. We will notify you of any extension and the reasons within one month of receiving your request.
Information requested under your rights in section 13 will be provided free of charge, unless otherwise provided for in section 13. If your request is unjustified or excessive, particularly if repeated, we may charge a reasonable administrative fee. We may also decline to act on the request.
If we have doubts about your identity, the Company may request further information to verify it.