Inklyn Propvale

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: 14.05.2026

We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website Inklyn Propvale (the "Website").

We want you to be able to make informed choices about the use and processing of Personal Data. We use various methods and procedures to provide you with relevant information. If we believe you need specific details, we will provide them at the appropriate date and time. We are happy to answer any questions you may have regarding any limitations imposed by law.

By using our Website, you confirm that you have read and accepted this Privacy Policy. For questions: support@inklyn-propvale.com

1. The Scope

1.1 This policy explains the types of Personal Data the Company collects from natural individuals and how it processes and shares it with third parties, secures it, and so on.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through additional information we have or can access.

1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data. It includes the handling, structuring, and storage of Personal Data.

1.4 Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect or seek information from any person younger than 18 years old. We do not knowingly permit such persons to use our services. If we become aware of any information about children, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 When you use the service and channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide Us with any Personal Data. In certain circumstances, however, you may choose not to provide Us with any Personal Data. This may prevent Us from providing the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.1 This includes information about your online activity and traffic data, including:

  • 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

4.2 The information you collect is not personal information and cannot be used to identify you.

4.3 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.

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

5.1 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 Without a legal basis, the Company cannot use Personal Data relating to you. The legal grounds on which the Company is able to process Personal Data relating to you:

  • You have consented 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 meet an obligation of law.

5.3 Contact us by email for more details about the processing required to protect legitimate interests.

5.4 Below is a list of reasons and legal grounds on which we may use the information you provide us with:

Scope

Legal Basis

To provide your personal information to third parties at your request to gain access to digital trading
If you request this, we may ask for your Personal Data to share it with third-party companies.

You have given your consent 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 answer any questions you may have about the Services.

The legitimate interests of the Company or those of a third party need to be processed.

3. To meet any legal, administrative or judicial obligation, Personal Data is processed to comply with legal requirements.

To ensure compliance with legal obligations, processing is required.

4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash or malfunction reports we collect in relation to the Services.

The legitimate interests of the Company or those of a third party need to be processed.

5. To stop fraud and misuse of Our Services.

The legitimate interests of the Company or a third party need to be processed.

6. To carry out and manage activities that align with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, etc.

The legitimate interests of the Company or those of a third party need to be processed.

7. To carry out analysis, including statistical analysis
To make decisions on various issues, we use different analytical techniques (including statistical methods).

The legitimate interests of the Company or those of a third party need to be processed.

8. To protect our assets, rights and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in accordance 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 Party

6.1 The Company may also provide Personal Data to third-party companies that offer services to us, such as hosting and storage providers, IP address information, as well as analysis of user experiences.

6.2 You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you have given Us to third-party trading platforms. The use of your Personal Data will be subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This can provide the Company with the resources it needs to enhance and improve the products and services it offers its customers.

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

6.5 We may also share your Personal Data with potential investors or buyers, or with 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 in the group) or as part of any merger, restructuring, consolidation or bankruptcy involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, such as those providing advertisements on our website or analytics services, may be used. These companies may also use cookies or other technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Certain cookies we may use are session cookies. They are temporarily downloaded to your device and will remain for a short period before you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period after you close your browser. They are used to help the Website identify you as a returning user and allow users to return to the website.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary to let you access the features you've requested and navigate our website. Cookies are used to deliver the information, products and services you have asked us 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've previously visited.

Additional Information

Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).

The type of cookie

Functionality Cookies

Scope

Cookies help us recognise you whenever you visit our site and save your preferences and settings.

Additional Information

They remain saved until the expiry date, even after the browser has been closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical data on the site's performance and help improve it. They also allow Us to analyse our website.

Additional Information

Cookies store anonymous data that is not linked to any identifiable or identified natural person. They can be removed when you close your browser. Other cookies remain valid indefinitely.

7.4 Cookies may be blocked or removed. To block or remove 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

7.5 However, please note that certain or all Website 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 Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing Personal Data, as described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and orders.

8.2 We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we'll continue sharing your data for another 12 months.

8.3 We regularly review the Personal Data we retain to ensure it is no longer needed.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country or to international organisations). Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that users can exercise their rights and access effective legal recourse.

These protections and safeguards are available to everyone residing in the EEA (European Economic Area):

  • Transfer to a third country or international organisation that the EU Commission has determined provides adequate security 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 made under a legally binding and enforceable agreement between public entities or authorities in 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

9.3 The Company can provide information on the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@inklyn-propvale.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss or alteration of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held accountable 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.

10.3 If required by law or due to other circumstances beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these cases, we cannot control the security of your Personal Data once it is in the hands of those third parties.

10.4 Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you send to Us via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website may include links to third-party sites and applications. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to actions taken through such sites or apps.

11.2 When you visit any third-party websites or apps, We recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest that you provide them with any Personal Data.

12. Modifications to This Policy

12.1 This Policy may be amended at any time. If we change this Policy, we will notify you by posting the updated Policy on our website.

12.2 In addition, if we make significant changes to this Policy, we will try to inform you using the methods we believe are appropriate and will publish an announcement on our website.

12.3 Unless explicitly stated otherwise, any amendments will take effect after the revised Policy is published.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 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 Personal Data. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of the Personal Data being processed about you. If it is, you are able 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 is detrimental to the rights and freedoms of another person or their rights, the Company can refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data relating to you be rectified, taking into account the reason for processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed for the purpose for which they were 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 your Personal Data based on legitimate interests pursued by Us or by a third party; (e) Personal Data are processed unlawfully; or (f) Personal Data must be removed to comply with the company's legal obligation. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that must be processed 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 ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, it may only be retained with your consent, or to establish, exercise or defend legal rights, to protect the rights of another natural person, or where there is an important public interest reason within the European Union or a Member State.

13.7 Right to data portability If processing is carried out by an automated system and is based on consent or on a contract to which you are a party, you have the legal right to review the Personal Data 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 exercising your right to data portability. The right to data portability does not interfere with the rights or freedoms of any other person.

13.8 Right to challenge You have the right at any time to object to any use 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 unless you show that your rights, freedoms, or interests override those grounds, or unless the processing relates to the exercise, establishment, or defence 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.

13.9 Right to refuse consent You may withdraw your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before it was withdrawn. You have the right to lodge a complaint with the authority that supervises you. You may also lodge an appeal 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 Member States may limit your rights in relation to Personal Data concerning you, as set out in this section 13.

13.10 We will provide you with the requested information in line with your rights under section 13 of this agreement within one month of receiving your request. This time frame may be extended by up to two months, if necessary, depending on the nature of the request as well as the number of requests. Within one month of receiving your request, we will notify you of any extension, as well as the reasons.

13.11 Provided this is not contrary to the provisions of section 13 of the law, the information you request in terms of your rights under section 13 will be made available free of charge. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative costs of providing the information or communicating the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request We may ask the person making the request to provide reasonable proof of identity.

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

Inklyn Propvale 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@inklyn-propvale.com