Privacy Policy

We are committed to being transparent about how we collect and process your personal information:

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use a range of methods to keep you informed about how your Personal Data is handled.
Where specific information is relevant to you, we will provide it at the appropriate time.
We're happy to answer any questions and clarify any limitations imposed by law. You can reach us at: info@brightendowmarine.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for several purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site; to protect our rights and interests; to maintain and support the Services; to meet applicable regulatory and legal obligations; and to carry out administrative and business activities necessary for the delivery and use of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights in relation to your Personal Data:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we are committed to employing a range of methods and measures to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes what personal data the Company collects about individuals, how it is processed, shared with third parties, and secured. This policy applies to information relating 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 the Company holds or can reasonably access. "Processing" refers to any operation involving personal data, including its collection, organisation, structuring, and storage. Our services are intended for users aged 18 and above. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. Depending on the context, we may request this directly from you, gather it by analysing how our services and channels are used, or receive it from our third-party partners.

You are not required to disclose personal information to us. However, please be aware that withholding certain information may prevent us from delivering our Services or granting you access to the website.

Providing personal data is not mandatory. However, choosing not to share it may prevent us from delivering our Services or restrict your access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information about your online activity log, technical data about your traffic (including IP address, date of access, and time of access), the language used, software crash logs, browser type, and details about the device you used. This information is non-personal and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide when you connect with a third-party online trading platform through Us.
Personal information you provide 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 Personal Data We process your personal data only when we have a valid legal basis to do so. The specific legal basis depends on the type of personal data involved and the context in which we collect it. We process personal data for the following reasons: — To perform our contractual obligations to you, or to take steps at your request before entering into a contract. — To comply with legal obligations to which we are subject. — Where processing is necessary to protect your vital interests or those of another person. — Where we have a legitimate interest in processing your personal data, provided that interest is not overridden by your rights and interests. — Where you have given your consent to the processing of your personal data for one or more specific purposes. Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Where providing personal data is a contractual or statutory requirement, or a requirement necessary to enter into a contract, failure to provide the requested data may prevent us from delivering our Services or granting you access to the website.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: With your explicit consent. When required to fulfil the contract we have entered into with you or a third party acting in your interest. When required by law, regulation, or a lawful order from a competent authority. When necessary to protect the vital interests of you or another person. When necessary for the performance of a task carried out in the public interest or in the exercise of official authority. When necessary for the legitimate interests pursued by us or a third party, except where those interests are overridden by your fundamental rights and freedoms. Third parties who receive your personal data are contractually required to handle it in accordance with applicable data protection obligations. We do not sell your personal data to third parties. Where personal data is transferred outside your jurisdiction, we ensure appropriate safeguards are in place to protect it in accordance with applicable law.

We may share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be shared as provided by you, and its subsequent use will be governed by the privacy policies of those platforms. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with affiliated entities or business partners where doing so enables us to improve and develop the products and services we offer.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share your Personal Data with prospective investors, acquirers, or lenders — in relation to the Company or any entity within its group — in connection with any proposed or completed transaction, including the transfer or sale of assets, merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Third-Party Services We use cookies and third-party services on our platform. Some of these services may collect data about your browsing behaviour and usage patterns, both on our website and across other sites. Third-party providers we work with may include analytics tools, advertising networks, and functional service providers. Each operates under its own privacy policy and data practices, which we encourage you to review. By continuing to use our website, you consent to the use of cookies and third-party services as described in this section. You may manage or withdraw your cookie preferences at any time through your browser settings or our cookie consent tool, though doing so may affect the availability of certain features. We do not control how third parties collect, store, or use your data once it leaves our platform. Any data shared with third parties is subject to their respective terms and privacy policies.

We may engage third-party service providers, including advertising partners and analytics companies, to support our website. These providers may also use cookies or similar tracking technologies.
Cookies are small text files placed on your device when you visit our website. They are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and tailor content and services to you. Cookies are also used for statistical and analytics purposes.
We use two types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognise you as a returning user and help you resume your activity on the website.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.
Your information will be shared with third-party trading platforms for 12 months. With your consent, this sharing will continue for a further 12 months.
We periodically review the personal data we hold to confirm it is no longer required.

Transfers of Personal Information to a Third-Party Country or International Organisation We may transfer your personal information to recipients located outside your country of residence, including in third-party countries or through international organisations. Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal information in accordance with applicable data protection requirements. These safeguards may include standard contractual clauses, binding corporate rules, or other legally recognised transfer mechanisms. By using our services, you acknowledge that your personal information may be transferred, stored, and processed in countries whose data protection laws may differ from those in your jurisdiction. We take reasonable steps to ensure that any third party receiving your personal information is bound by confidentiality obligations and provides an adequate level of protection. If you require further information about the specific safeguards applied to cross-border transfers of your personal information, you may contact us through the details provided in this policy.

10. Security of Personal Data We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, or disclosure. While we apply commercially reasonable safeguards, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal data. You are responsible for keeping your account credentials confidential. If you believe your account has been compromised, notify us immediately. We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. When personal data is no longer needed, we dispose of it securely. In the event of a personal data breach that poses a risk to your rights and freedoms, we will take prompt action in accordance with our legal obligations, which may include notifying the relevant authorities and affected individuals where required.

We have taken appropriate organisational and technical measures to protect your Personal Data, including safeguarding against accidental or unlawful destruction, loss, or modification.
We cannot guarantee that the security of your Personal Data will be maintained 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, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where legal or other obligations beyond our control require it, we may be required to disclose your Personal Data to third parties, including public authorities. We have no control over the security measures applied to your Personal Data by such third parties.
No method of transmitting Personal Data over the internet is entirely secure. We cannot guarantee the security of Personal Data you transmit to us online.

11. Links to Third-Party Websites

Our website may contain links to third-party websites and applications. These external sites and apps 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 apps.
Before accessing or using any third-party website or app, we recommend reading their privacy policy carefully. We also advise caution when sharing any Personal Data with them.

12. Modifications to This Policy We may update this Policy from time to time. When we do, we will revise the effective date at the top of this page. If changes are material, we will notify you by email or through a prominent notice on our platform prior to the changes taking effect. Your continued use of our services after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how we protect your information.

Before accessing any third-party websites or apps, read their privacy policies carefully. Only provide your personal data to them once you are satisfied with how it will be handled.

13. Your rights with respect to your personal information Depending on your location and applicable law, you may have certain rights regarding the personal information we hold about you. These rights may include: The right to access the personal information we hold about you and to receive details on how it is used. The right to request correction of any inaccurate or incomplete personal information. The right to request deletion of your personal information, subject to certain legal exceptions. The right to object to or restrict how we process your personal information in certain circumstances. The right to data portability, meaning you may request that we transfer your personal information to you or a third party in a structured, commonly used format. The right to withdraw consent at any time where processing is based on your consent, without affecting the lawfulness of processing carried out prior to withdrawal. The right to lodge a complaint with a relevant supervisory or data protection authority if you believe your rights have been violated. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request. Please note that some rights are not absolute and may be subject to limitations under applicable law. In certain cases, we may be unable to fulfill a request — for example, where doing so would conflict with a legal obligation or adversely affect the rights of another person. We will not discriminate against you for exercising any of your rights.

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope or types of processing applied to your Personal Data.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please send a written request to the email address below.
Access Rights
We can confirm whether your Personal Data is being processed. If it is, you may request access to that data.
We will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, we may decline or limit our response.
Right to Rectification
We will correct inaccurate Personal Data upon request. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is processed.
Right to Erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal rights.
Right to Restriction of Processing
If you have concerns about the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal rights, or to protect the rights of another individual, or on grounds of significant public interest within the European Union or a Member State.
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 the Personal Data you have provided to us in a structured format.
You may 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 does not override the rights or freedoms of others.
Right to Object
You have the right to object at any time to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by us or a third party, including profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds that override your rights, interests, or freedoms, or that relate to the establishment, exercise, or defence of legal rights, we will cease such processing.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
Right to Withdraw Consent
You may withdraw your consent to 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 the relevant supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals' fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit the rights described in this section 13 as they apply to your Personal Data.
We will respond to requests made under the rights in section 13 within one month of receipt. Where necessary, this period may be extended by up to two additional months depending on the complexity and volume of requests. We will notify you of any extension, along with the reasons for it, within one month of receiving your request.
Unless contrary to the provisions of section 13, information provided in response to requests under section 13 will be supplied free of charge. Where requests are manifestly unfounded or excessive, in particular where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubts about the identity of the person submitting a request, we may ask for additional information to verify identity.