Fundbrook Assets

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: 14.07.2026

We (also referred to as "We", "Us" or "Our") are committed to safeguarding your Personal Data and privacy. This Privacy Policy explains how we collect and store the information you provide through the website Fundbrook Assets (the "Website").

We want you to be able to make informed choices about the use and processing of Personal Data. We use different 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 available to answer any questions you may have, subject to any limitations imposed by law.

By using our Website, you confirm that you have read and agree to this Privacy Policy. Questions: support@fundbrookassets.com

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects about natural individuals, how it processes and shares it with third parties, how it secures it, and related matters.

1.2 This Policy applies to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we have or can access.

1.3 Under this Policy, "processing" means a process that requires the use or gathering of Personal Data. This includes managing, structuring, and storing Personal Data.

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

2. What Personal Data Do We Have on You

2.1 If you access the service and channels or visit our website, we collect Personal Data. We may request your Personal Data in certain instances.

2.2 In other instances, we gather your Personal Data by analysing your use of our Services or our service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. In certain circumstances, however, if you do not supply Us with 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 from your online activity log and data about your traffic, 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 private information and cannot identify you.

4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect through Us with a third party online trading platform.

4.4 Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 The company processes your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.

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

  • You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information via the Website so we can transfer it to a third-party trading platform.
  • The Company or a third-party may require processing to meet their legitimate interest. For example, processing may be necessary to improve Our Services or defend legal claims.
  • Processing must meet an obligation of law.

5.3 Contact Us via email for more details on the processing necessary to safeguard the legitimate interests.

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

Scope

Legal Basis

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

You have given your consent to the processing of your Personal Data for one or more reasons.

2. To answer your requests, questions or concerns
Personal Data is necessary to respond to any questions you may have regarding the Services.

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

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

To ensure compliance with legal obligations, processing is required.

4. To enhance Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, any crash or malfunction reports we collect in relation to the Services.

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

5. To stop fraud and misuse of Our Services.

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

6. To perform and manage actions consistent with the requirements of Our Services
These include back-office functions, business development activities, strategic decision-making, oversight mechanisms, and similar activities.

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

7. To conduct analysis, such as statistical analysis
To make decisions on different issues, we use different analytical techniques, including statistical techniques.

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

8. To safeguard our assets, rights and interests, and those of third parties
We may process Personal Data to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.

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

6. Transfer of Personal Data to Third Party

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

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 provide to Us to third-party trading platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data could be shared with multiple trading platforms.

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

6.4 Where necessary to safeguard the rights of third parties or assets, The Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company in the group if such a transaction occurs (including the transfer or sale of assets of the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, including advertising providers on our website and analytics companies, may be used. These companies may also use cookies or other technology.

7.2 Cookies are tiny text files placed on your device when you visit or access the website. Cookies gather information about your preferences and browsing habits to improve the user experience, remember your preferences, and customise products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period until you close your browser. Other cookies are persistent. Persistent cookies remain 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 enable you to return to the Website.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary for you to access the features you have requested and to navigate our website. We use cookies to provide the information, products and services you have requested.
They are required for your device to download and stream data. This allows you to navigate the website, use its features, and return to pages you have previously visited.

Additional Information

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

The type of cookie

Functionality Cookies

Scope

Cookies allow us to recognize you each time you visit our site and save your preferences.

Additional Information

They remain stored until their expiry date, even after the browser is 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 associated with any identified or identifiable natural person. Some are removed when you close your browser. Other cookies remain valid indefinitely.

7.4 Cookies can be blocked or removed. To block or remove cookies, you need to change your browser's settings. Below are links to help you with the process for several well-known browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please be aware that some or all Website functions and features may not work as expected 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 Personal Data about you 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 law, regulations, policies, and applicable orders.

8.2 We will share your information with trading platforms operated by third parties for a period of 12 months. If you agree to this, we will continue to share your data for another 12 months.

8.3 We regularly review Personal Data that we have kept to ensure that 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 transmitted to a third country or to international organizations). The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users 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 determined provides adequate security for Personal Data transferred to it under 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, pursuant to Article 46(2)(a)
  • The transfer was carried out in accordance with the common data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

9.3 The Company can provide information about the security measures it uses to safeguard your Personal Data when it is transferred to third-party countries or international organisations. Send an email to: support@fundbrookassets.com

10. Security of Personal Data

10.1 We have taken appropriate organisational and technical precautions to safeguard Personal Data, including measures to prevent the accidental or illegal destruction, loss or modification 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 Where legal obligations or other obligations beyond our control apply, we may be required to provide Personal Data concerning you to third parties, such as public authorities. In these situations, we cannot control the security third parties provide for your Personal Data.

10.4 Personal Data cannot be transferred over the web with complete security. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party sites and applications are provided on the website. These applications and websites are not under the supervision of the Company. We are not responsible for the gathering or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.

11.2 When you access any third-party websites or apps, we recommend reading their privacy policies before deciding to use them or provide any Personal Data to them.

12. Modifications to This Policy

12.1 This Policy is subject to change at any time. If we change this Policy, we will notify you of the changes by posting the updated Policy on our website.

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

12.3 Unless explicitly specified, any amendments will become effective after publication of the revised Policy.

13. Your Rights

13.1 You are entitled to request that we verify the accuracy of Personal Data being collected about you, rectify any mistakes, and delete all Personal Data not required by Us. You may also restrict the scope of processing types for personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights are available to you with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by emailing the address below.

13.3 Access rights The Company can verify whether Personal Data about you is being processed. If it is, you may 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. If requested, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request adversely affects another person’s rights and freedoms, the Company may refuse to comply with the request or limit its fulfilment.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You are entitled to demand rectification of any insufficient Personal Data concerning you, taking into account the reason for processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer required 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 a reason specific to your situation, to the processing of Personal Data about you based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet a lawful obligation of the company. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to create, exercise or defend legal rights.

13.6 Processing restrictions If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit the processing of your Personal Data. If you ask for Personal Data to be restricted, Personal Data may only be kept with your consent; to create, exercise, or defend legal rights; to defend the rights of another natural individual; or for reasons of significant public interest 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 your consent or on a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You may request that the Company transfer your Personal Data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not interfere with the rights or liberties of anyone else.

13.8 Right to challenge You have the right to object at any time 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 can establish compelling legitimate grounds for processing Personal Data, we cannot continue doing so unless you can prove that those grounds outweigh your rights, freedoms, or interests, or relate to the exercise, establishment, or defense of legal rights. For 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 revoke your consent to Us processing Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before its withdrawal. You are entitled to lodge a complaint with the authority that supervises you. You may appeal to a supervisory authority established by a member state to safeguard individuals' fundamental rights 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 detailed in this section 13.

13.10 We will provide the requested information in accordance 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 and the number of requests. We will notify you of any extension and the reasons within one month of receiving your request.

13.11 Unless contrary to the provisions of section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unjustified or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or communicating the requested action. We may also refuse to act.

13.12 If we have doubts regarding the identity of the real person who submitted your request, we may ask the person making the request to provide reasonable means of identifying themselves.

This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.

Fundbrook Assets 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@fundbrookassets.com