Privacy Policy

Our commitment

We – referred to as «We» or «Our» – are committed to protecting your personal information and your privacy.

This privacy policy is designed to explain how we collect, store, process and use the information you provide in connection with the website Keystone Luxent (hereinafter «the Website»).

We are committed to the following principles:

Transparency in the collection and processing of your personal information:

We ensure you are always well informed so you can make informed choices about how your data is used on the website or when you interact with third-party platforms. We use various methods to provide you with accurate and timely information about the processing of your data.

If we need to provide you with specific information, we ensure it is delivered at the right time and place.

We are also available to answer questions or provide clarification, within the framework of applicable law. You can reach us by email: [email protected]

Processing of personal information only for the purposes set out in this policy:

We may process your information to make the website available, connect you to third-party trading platforms («the Services»), improve the user experience, develop the platform, protect our rights, carry out administrative processes and meet legal requirements.

We also process information to better understand your needs and preferences.

Resources to uphold your rights:

We dedicate significant resources to ensure you can exercise your rights as a data subject. You may at any time request access, correction, deletion or restriction of your information, or request its transfer. We will respond in accordance with applicable law.

Protection of your personal information:

Although we cannot guarantee absolute security, we use modern security methods and measures to protect your information and will continue to improve them.

Our full privacy policy

1. Scope

This policy describes what types of data we collect, how we process it, share it with third parties, and what security measures we apply.

«Personal information» means any information that can be linked to an identified or identifiable person. «Processing» means any operation such as collection, storage, use, sharing, adjustment or deletion.

Our services are intended for a general audience and are not directed at persons under 18 years of age. We do not knowingly collect information from minors. If we discover that such information has been recorded, we will delete it as soon as possible.

2. When do we collect information?

We collect data when you use our services, visit the website or interact with our channels. Some information you provide yourself; other information is collected automatically through analysis of your activity or via third-party partners.

3. No obligation to provide data – but consequences

You are not required to provide us with information. However, without certain data we cannot offer you all our services or give you full access to the website.

4. What types of information do we collect?

This may include activity logs, IP addresses, timestamps, language, browser type, device information and error logs. Some of this may not identify you directly and is therefore not considered personal information.

Information you give us directly: name, phone number, email address when you contact us or use the platform.

5. Purpose of processing and legal basis

Keystone Luxent processes information only when we have a lawful basis, for example to deliver services, improve the experience, protect your data, or fulfil legal obligations.

• You have given consent to the processing of your personal information for specific purposes. This applies when you knowingly share information via the website so that we can forward it to a third-party trading platform.
• Processing is necessary to pursue legitimate interests of Keystone Luxent or a third party. For example, this may include improving our services or handling legal claims.
• Processing is necessary to comply with a legal obligation to which Keystone Luxent is subject.

If you would like a clearer explanation of how the processing of your personal information serves legitimate interests of Keystone Luxent or a third party, you may contact us by email at any time.

Below is an overview of why we may process your information, together with the legal bases:

6. Transfer of personal information to third parties

Keystone Luxent may share your information with third-party providers who assist with storage, hosting, IP information, user experience analytics, research and other technical or diagnostic services.

If you request it, we may also transfer certain information to third-party trading platforms. In such cases they will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.

Keystone Luxent may also share information with affiliated companies and business partners who help improve the quality of our services.

We may disclose information to public authorities if necessary to protect our or third parties’ interests, rights or assets, including in connection with legal proceedings.

Information may also be shared with potential buyers, investors or lenders in connection with merger, acquisition, reorganisation or insolvency proceedings.

7. Cookies and third-party services

We use certain third-party services, such as analytics and advertising providers. These may use cookies or similar technology, governed by their own policies.

A cookie is a small text file stored on your device when you visit the website. It may collect information about usage patterns, preferences and technical data, and is used to improve your experience, remember settings and deliver more relevant content.

We may use both session cookies (deleted when you close the browser) and persistent cookies (which remain on your device until they expire or you delete them manually).

Types of cookies:

Blocking and deleting cookies

You can change your browser settings to block or delete cookies. Here are links to instructions for the most commonly used browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some website features may stop working if you block cookies.

NOTE ON ONLINE TRACKING

This service does not currently support «Do Not Track» signals.

8. Storage of personal information

Keystone Luxent will store your information for as long as necessary for the purposes described in this policy, or as required by law, regulation or authority.

If you have given consent, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension after renewed consent.

We regularly review stored information to ensure it is not kept longer than necessary.

9. Transfer of personal information to third countries or international organisations

Your personal information may be transferred to a third country (outside the EEA) or to international organisations. In such cases Keystone Luxent will implement necessary safeguards to ensure the information is protected and that you retain your rights and effective remedies.

If you are resident in the EEA (European Economic Area), such safeguards will apply if one of the following criteria is met:

• The transfer is to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for personal data, pursuant to GDPR Article 45(3).
• The transfer is made under a legally binding and enforceable agreement between public authorities or bodies, pursuant to GDPR Article 46(2)(a).
• The transfer is based on standard data protection clauses adopted by the European Commission, pursuant to GDPR Article 46(2)(c). You can find these clauses on the European Commission’s website.

If you would like more information about what safeguards we use when transferring personal information, you can contact us by email: [email protected]

10. Protection of personal information

We use technical and organisational security measures to protect personal information against unauthorised access, alteration, loss or destruction. These measures are tailored to the risk of the processing.

We cannot guarantee absolute security for data transmission over the internet. Keystone Luxent disclaims liability for indirect or unintended damage that may arise from data loss or unauthorised access beyond our reasonable control.

In some cases we may be legally required to share information with public authorities. In such cases our level of control over the protection of the information may be limited.

11. Links to third-party websites

The website may contain links to external websites or applications operated by third parties. Keystone Luxent has no control over these and is not responsible for their processing of personal information. We recommend that you always read their privacy policies before providing any information.

12. Your rights regarding personal information

You have the right to request access to what information we process about you, to request correction of errors, to request deletion of data that is no longer necessary, and to restrict or withdraw consent to certain processing.

Right of access

You have the right to obtain confirmation as to whether Keystone Luxent processes personal information about you. If we do, you have the right to access the information and to be informed about: purpose, data types, recipients (including in third countries), storage period, your rights, right to complain and what safeguards are in place for transfers.

You may receive a copy of the information being processed. If you request additional copies, we may charge a reasonable fee. If the request is sent electronically, you will normally receive the data in a commonly used electronic format.

The right of access must not adversely affect the rights and freedoms of others. If it does, we may limit access or refuse the request.

Right to rectification

You may request that Keystone Luxent correct inaccurate or incomplete information about you. You may also add a supplementary statement if needed.

Right to erasure («right to be forgotten»)

You have the right to request erasure of your information when it is no longer necessary to process it, when you withdraw consent, or if the processing is unlawful. We will respond in accordance with applicable law.

Right to erasure («right to be forgotten»)

This right applies if: (a) the personal information is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or a third party’s legitimate interests and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the information has been processed unlawfully; or (f) the information must be erased to comply with a legal obligation under EU or applicable law.

The right does not apply if processing is necessary (a) to comply with a legal obligation, or (b) for the establishment, exercise or defence of legal claims.

Right to restrict processing

You may request that we restrict the processing of your information if: (a) you contest its accuracy, for a period that allows us to verify it; (b) the processing is unlawful but you prefer restriction to erasure; (c) we no longer need the information but you need it for legal claims; (d) you have objected to the processing, pending verification of our legitimate interests; (e) the information is processed for direct marketing, including profiling.

If processing is restricted, the information may only be used with your consent, for legal claims, to protect the rights of others, or for important reasons of public interest.

Right to data portability

You have the right to receive personal information you have provided to us in a structured, commonly used and machine-readable format. You may also request that the information be transferred directly to another controller where technically feasible and where processing is based on consent or contract and is carried out by automated means.

Right to withdraw consent

You may withdraw consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to object

You may object to the processing of your information when processing is based on legitimate interests. This also applies to profiling. We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests and rights, or the processing is necessary for legal claims.

You may also object at any time to the processing of information for direct marketing, including profiling related to such marketing.

Right to complain to a supervisory authority

You may complain to the OAIC (Office of the Australian Information Commissioner) or another supervisory authority within the EEA if you believe the processing of your personal information violates applicable data protection law.

We will respond to requests to exercise your rights within one month of receipt. Where necessary, the period may be extended by up to two months depending on the complexity and number of requests. You will be informed of the reason for any delay.

Information related to the exercise of rights is provided free of charge unless the request is manifestly unfounded or excessive. In such cases we may charge a reasonable fee or refuse the request.

Keystone Luxent may request additional information to verify your identity if we have reasonable grounds to doubt it.

13. Updates to this policy

We reserve the right to update this privacy policy. Changes will be published on the website, and we will inform you of significant updates in a clear manner. Unless otherwise stated, changes take effect when the updated policy is published.