Privacy Policy

We are committed to being transparent about how we collect and process your personal data.

We want you to be informed about how your Personal Data is used and processed. To support this, we use a range of methods to keep you provided with relevant, timely information. Where specific details are needed, we will provide them at the appropriate time. If you have any questions or require clarification regarding any legal limitations that apply, please contact us at: info@brightkeepsomery.com

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

We process your personal data for a range of 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 support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities related to 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, you have access to the following tools:

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

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 techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the personal data the Company collects about natural individuals, and how that data 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 one 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 the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18, and we do not knowingly permit such individuals to use our services. If we become aware that we hold information relating to a child, we will delete it as promptly as possible.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. This may occur directly, when we request it from you, or indirectly, through analysis of how you use our services and channels, or via information received from our third-party partners.

You are not required to provide personal information to the company. However, please be aware that choosing not to do so may prevent us from delivering our Services or granting you access to the website.

You are not obliged to provide us with any personal data. However, choosing not to do so may prevent us from delivering our Services or granting you 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, traffic data (such as IP address, access dates and times), language settings, software crash logs, browser type, and device information. This data is not personal information and cannot be used to identify you.
Personal Data we receive from you: any personal data you choose to provide when connecting to a third-party online trading platform through us.
Personal information provided to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances. Service Providers: We work with carefully selected third-party companies and individuals who perform services on our behalf, including payment processing, data analysis, email delivery, hosting, customer support, and marketing. These parties have access to your personal data only to perform those functions and are not permitted to use it for any other purpose. Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your personal data is transferred and becomes subject to a different privacy policy. Legal and Regulatory Obligations: We may disclose your personal data where required to do so by law or in response to valid requests from public authorities. Protection of Rights: We may disclose your personal data where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to personal safety, or violations of our Terms of Service. Third-Party Analytics: We may share aggregated or de-identified information — which cannot reasonably be used to identify you — with third parties for marketing, advertising, research, or similar purposes. Where your personal data is transferred to third parties, we take reasonable steps to ensure it is handled securely and in accordance with this Privacy Policy.

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 will transmit specific Personal Data to third-party trading platforms. Once shared, your Personal Data is governed by the privacy policies of those platforms. Your Personal Data may be disclosed to more than one trading platform.
We may share Personal Data with affiliated entities or business partners where this supports the development and improvement of our products and services.
We 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 prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within the group — in connection with a sale or transfer of assets, merger, restructuring, consolidation, or insolvency event involving the Company or any group company.

7. Cookies and Third-Party Services We use cookies and services provided by third parties on our website. These third parties may collect and process personal data in connection with their services. Where this occurs, those third parties act as independent data controllers and are responsible for their own data processing activities. You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Please note that disabling certain cookies may affect the functionality of our website. Where we use third-party services, we take reasonable steps to ensure those providers offer an adequate level of data protection. However, we are not responsible for the privacy practices of third-party websites or services that are linked to or integrated within our platform. We encourage you to review their privacy policies directly.

We may engage third-party service providers, such as advertising networks and analytics companies, to support our website. These providers may also use cookies or similar technologies. Cookies are small text files placed on your device when you visit our website. They are used to gather information about your preferences and browsing behaviour, personalise your experience, and support statistics and analytics. 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 allow the website to recognise you as a returning user, making it easier to access the website again.

Types of Cookies:

We may use them according to their purpose.

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

We will 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, regulation, or order.
Your information will be shared with third-party trading platforms for 12 months. Where you provide consent, this sharing will continue for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Data to a Third Country or International Organisation

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Access to your personal data is restricted to employees, agents, contractors, and third parties who have a legitimate business need to process it. They are subject to a duty of confidentiality and will only process your personal data on our instructions. We have procedures in place to handle any suspected personal data breach. Where we are legally required to do so, we will notify you and any applicable regulator of a breach. No transmission of data over the internet is entirely secure. While we take all reasonable steps to protect your personal data, we cannot guarantee the security of data transmitted to our website. Any transmission is at your own risk. Once we have received your data, we apply strict procedures and security features to prevent unauthorised access.

We have implemented appropriate organisational and technical measures to protect Personal Data, including against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we accept liability for any intangible, 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 Personal Data to third parties, such as public authorities. In such circumstances, we cannot control the level of security those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website contains links to third-party websites and applications. These 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 them.
Before accessing or using any third-party website or application, we recommend reading their privacy policy carefully and considering what personal data, if any, you choose to share with them.

12. Modifications to this Policy We may update this Policy from time to time. When we do, we will revise the date at the top of this page. Where changes are material, we will notify you by email or through a prominent notice on our website 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 or using any third-party websites or apps, we recommend reading their privacy policies. You should also consider carefully what personal data you share with them.

13. Your rights with respect to your personal information

You have the right to request that we verify the accuracy of Personal Data held about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types or scope 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 contact us by email at the address below.
Access rights
The Company can verify that your Personal Data is being processed and, where it is, provide you with access to that data.
We will supply an electronic copy of the Personal Data currently being processed. A reasonable fee may be charged for additional copies. Data will be provided in electronic format upon request.
The right of access must not infringe on the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its response accordingly.
Right to rectification
You have the right to request the correction of inaccurate Personal Data held about you. Where Personal Data is incomplete, you may request that it be completed, taking into account the purposes of processing.
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 there is no other legal basis for processing; (c) you object, on grounds specific to your situation, 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 claims.
Processing restrictions
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 to establish, exercise, or defend legal claims, to protect the rights of another individual, or where there is a substantial public interest under European Union or Member State law.
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 party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used 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, and the right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defence of legal claims, we will cease such processing.
Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you 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 a supervisory authority established by a Member State to oversee the protection of individuals' rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit the rights described in this section in relation to Personal Data concerning you.
We will respond to requests made under the rights set out in this section within one month of receipt. Where necessary, given the complexity or volume of requests, this period may be extended by up to two additional months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.
Unless otherwise provided under this section, information provided in response to your rights requests 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 on the request.
Where we have reasonable doubt as to the identity of the person submitting a request, we may ask for additional information to verify identity before proceeding.