Noble Venmere

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: 09.06.2026

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 Noble Venmere (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 require specific details, we will provide this information at the appropriate date and time. We are happy to answer any questions you may have, subject to any limitations imposed by law.

By using our Website, you confirm you have read and agree to this Privacy Policy. For questions, contact support@noble-venmere.com

1. The Scope

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

1.2 This Policy concerns information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or in combination with additional information we hold or can access.

1.3 The Policy defines "processing" as a process that requires the use or gathering of Personal Data, including the management, 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 seek or collect information from anyone younger than 18 years old. We do not knowingly allow such persons to use our services. If we discover 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. In certain instances, we may request your Personal Data.

2.2 In other instances, we gather your Personal Data by analysing your use of 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 obliged to provide Us with any Personal Data. However, in certain circumstances, not providing Personal Data may prevent Us from offering 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 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 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 to a third party online trading platform through Us.

4.4 Personal information you provide specifically to third-party platforms to facilitate trading: 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 legal basis applicable to that processing.

5.2 Without a legal basis, the Company cannot use Personal Data concerning you. The legal grounds on which the Company may 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 your Personal Data via the Website so we can transfer it to a third-party trading platform.
  • The Company or a third-party may require processing to pursue 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 by email for further details about the processing necessary to safeguard the legitimate interests.

5.4 Below is a list of the reasons and legal grounds on 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 request Personal Data from you and forward it to third-party companies.

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

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

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

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

To ensure compliance with legal obligations, processing is required.

4. To enhance Our Services
Personal Data may be used by us to enhance Our Services. This includes, among other things, any crash or malfunction reports that 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 activities that align with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.

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

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

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

8. To safeguard our assets, rights and interests, as well as 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 the interests of a third party.

6. Transfer of Personal Data to Third Party

6.1 The Company may also provide Personal Data to third-party companies that provide services to us, including hosting and storage providers, IP address information, and 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 cases, 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 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 needed to enhance and improve the products and services it provides to its customers.

6.4 If 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 of companies if such a transaction takes place (including the transfer or sale of assets belonging to 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, such as those that provide advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.

7.2 Cookies are small text files placed on your device whenever you visit or access the website. Cookies collect information about your preferences and browsing habits to improve the user experience, remember your preferences, and customise products and services you might 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 last 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 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, allowing you to move around 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. These session Cookies are erased once you close your web browser.

The type of cookie

Functionality Cookies

Scope

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

Additional Information

They remain until their expiry date and are saved 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 conduct analysis on our website.

Additional Information

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

7.4 Cookies can be blocked or removed. To block or remove cookies, update your browser settings. The links below can help you with this process for several widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, be aware that some or all Website functions and features may not operate 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 12 months. If you agree, we will continue to share your data for another 12 months.

8.3 We regularly review the Personal Data we retain to confirm 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 international organizations). The Company takes all necessary steps to safeguard the Personal Data you provide and ensure that data users can assert their rights and access effective legal recourse.

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, 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 pursuant to Article 46(2)(a)
  • The transfer was carried out in compliance with 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@noble-venmere.com

10. Security of Personal Data

10.1 We have taken appropriate organisational and technical precautions to safeguard Personal Data. This includes preventing 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 are not accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, any Personal Data disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.

10.3 Where we are subject to legal obligations or other obligations beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In these situations, we cannot control how third parties secure your Personal Data.

10.4 Personal Data cannot be transferred over the internet in a completely secure manner. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 The website provides links to third-party sites and applications. These websites and applications are not under the Company's supervision. 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 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 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 the Personal Data collected about you, rectify any mistakes, and delete all 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 with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights You may ask the Company to confirm 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. The data will be provided electronically if you request it. 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 how it fulfils it.

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 to process them; (c) You object at any time, for a reason specific to your situation, to the processing of Personal Data about yourself based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet the company's legal obligation. 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 may ask that the Company limit the processing of your Personal Data. If you request this restriction, 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 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 legal right to receive and review the Personal Data you have provided to the Company. You may also request that your Personal Data be transferred directly from the Company 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 adversely affect the rights or freedoms of others.

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 the 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 may continue processing only if you can prove that those grounds outweigh your rights, freedoms, or interests, or the exercise, establishment, or defence 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 the processing by Us of 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 have the right to lodge a complaint with your supervisory authority. You may lodge an appeal with 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 where necessary, depending on the nature of the request and the number of requests received. We will notify you of any extension and the reasons for it within one month of receiving your request.

13.11 Unless contrary to the provisions of section 13 of the law, the information you request pursuant to your rights under section 13 will be provided at no cost. If a 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 about the identity of the actual 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.

Noble Venmere 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@noble-venmere.com