Privacy Policy

1. The Scope

This policy describes the types of personal data the Company collects about natural individuals, including 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 directly identified, or identified through a combination of 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 organization, 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 individuals under 18, nor do we permit them to use our services. If we become aware that such information has been collected, we will delete it promptly.

2. What Personal Data Do We Have on You

2.1 When you access our services, channels, or website, we collect Personal Data. In certain instances, we may also request Personal Data directly from you.

2.2 We also collect your personal data by analyzing 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

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 to a third-party online trading platform through us.

4.4 Personal information you provide directly to 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 about the processing carried out to protect legitimate interests, please contact us by email.

5.4 The following outlines the reasons and legal grounds on which we may use the information you provide to us:

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 analyze IP address information and user experience data.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the relevant Personal Data you have submitted to us directly to those platforms. Your Personal Data may be shared with more than one trading platform, and its use will be governed by each platform's own privacy policy.

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.

6.4 The Company may disclose Personal Data to regulatory, local, or other official authorities where necessary to protect the rights or assets of third parties.

We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction — including a transfer or sale of assets, merger, restructuring, consolidation, or bankruptcy involving 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 habits to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistics and analytics.

7.3 We use two types of cookies. Session cookies are temporary and are removed from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognize you as a returning user, allowing the website to restore your previous session.

7.5 Please note that disabling cookies may cause some or all Website features to function incorrectly or not at all.

Online Tracking Notice: This service does not currently recognize 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 any longer period permitted by applicable law, regulations, or orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.

We periodically review the Personal Data we hold to determine whether it is still needed.

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 that you retain the right 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@keenmeritholdist.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, disclosure resulting from transmission errors, unauthorized third-party access, or other causes beyond our control.

10.3 In certain circumstances, legal or other obligations beyond our control may require us to disclose your personal data to third parties, such as public authorities. In these situations, we have no control over how those third parties handle the security of your personal data.

10.4 Transmitting Personal Data over the internet carries inherent security risks. The Company cannot guarantee 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. These sites and applications 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 such sites or applications.

11.2 When visiting any third-party websites or apps, review their privacy policies before accessing or using their services. Exercise caution when sharing any personal data with them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, the revised Policy will be posted on our website.

12.2 When significant changes are made to this Policy, we will notify you through appropriate channels and publish an announcement on our website.

Unless otherwise specified, amendments to this Policy take effect upon publication of the revised version.

13. Your Rights

You have the right to request verification of the accuracy of your Personal Data we collect, to correct any inaccuracies, and to delete any Personal Data we no longer require. You may also restrict the scope of processing of your Personal Data.

If you are an EEA resident, please refer to this page for details on your rights regarding your Personal Data. To exercise any of these rights, contact us at the email address below.

13.3 Access rights The Company may verify the accuracy of Personal Data being processed about you. Where applicable, you have the right to 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. The right of access must not conflict with the rights and freedoms of others. Where a request would be detrimental to the rights or freedoms of another individual, the Company may refuse or limit its response accordingly.

13.4 Right to rectification We may correct inaccurate Personal Data at any time. You have the right to request correction of incomplete Personal Data relating to you, 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 to the processing of your Personal Data based on legitimate interests pursued by Us or by a third party, and no overriding legitimate grounds exist; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation applicable to 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 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 significant 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 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 challenge You have the right at any time to object to any processing of your Personal Data that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. If we demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defense of legal rights, 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 Refuse Consent You may withdraw your consent for our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that withdrawal. You have the right to lodge a complaint with your applicable 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. EU and Member State laws may limit the rights described in this section 13.

We will provide the information you are entitled to under Section 13 of this agreement within one month of receiving your request. If the complexity or volume of requests requires it, this period may be extended by up to two additional months. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

Provided your request is not unjustified or excessive, the information you request under section 13 will be provided free of charge, subject to the provisions of that section. For requests that are unjustified or excessive — particularly repeat requests — we may charge a reasonable fee to cover administrative costs, or we may decline to act.

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