Privacy Policy

We are committed to protecting your personal data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://boldledgerontary.com (the Bold Ledgerontary).
The following principles apply:

We want you to be fully informed about how your Personal Data is used and processed. We use various methods to keep you informed and will provide specific details when relevant. If you have questions about any legal limitations that apply, we're happy to help.

1. The Scope?

This policy describes the types of personal data Bold Ledgerontary collects about individuals, and how that data is processed, shared with third parties, and protected.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be recognised directly or through a combination of information we hold or can reasonably access.
"Processing" refers to any operation involving personal data, including its collection, organisation, storage, and management.
Our services are intended for users aged 18 and over. 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. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our services and channels, or via information received from our third-party partners.

3. You are not required to share personal information with us. However, choosing not to may limit our ability to provide our services or grant you access to the website.

You are not required to provide us with personal data. However, withholding it 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 may collect the following personal data about you:

This includes information collected automatically when you visit our platform, such as your IP address, access date and time, language preference, browser type, software crash logs, and device information. This data is non-personal and cannot be used to identify you.
Personal data we receive from you: any personal data you voluntarily 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

Scope, Legal Basis

6. Sharing Personal Data with Third Parties We may share your personal data with third parties in the following circumstances. Service providers and business partners: We work with trusted third-party service providers and business partners who support our operations. These parties process personal data only as needed to perform their services and are bound by confidentiality and data protection obligations. Legal and regulatory requirements: We may disclose personal data where required by law, regulation, or a lawful request from a government authority or regulator. Business transfers: If we undergo a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction. We will notify you of any such change in accordance with applicable requirements. Protection of rights: We may share personal data where necessary to protect the rights, property, or safety of our company, our users, or others. With your consent: We may share personal data with third parties where you have given your explicit consent. In all cases, we take reasonable steps to ensure that third parties handle your personal data securely and in a manner consistent with this policy.

We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers and user experience analytics services. At your request, we will share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be governed by those platforms' privacy policies. Your Personal Data may be shared with more than one trading platform. We may also share Personal Data with related entities or business partners where this enables us to develop and improve 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 official authorities. We may share your Personal Data with prospective investors, acquirers, or lenders in connection with any proposed or completed transaction — including the transfer or sale of assets belonging to the Company or any entity within the group — or in connection with any merger, restructuring, consolidation, or insolvency event affecting the Company or any other entity within the group.

7. Third-party cookies and services

We may engage third-party service providers, including advertising networks and analytics companies, to support the operation of this website. These providers may also use cookies or similar tracking technologies. Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences in order to improve your experience, remember your settings, and personalise the content and services presented to you. Cookies are also used for statistical and analytics purposes. There are two types of cookies we may use. Session cookies are temporary and are removed 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, enabling a smoother experience on subsequent visits.

Types of Cookies:

We may use them according to their intended purpose.

Online Tracking Notice
This service does not currently support do-not-track signals.

8. How we retain 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 required or permitted by applicable law, regulations, or orders.
Your information will be shared with third-party trading platforms for 12 months. If you consent to continued sharing, we will extend this for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

9. Transfers of personal information to a third-party country or to an international organisation

10. Protecting Your Personal Data We take the security of your personal data seriously and use a range of technical and organisational measures to protect it against unauthorised access, loss, misuse, or disclosure. No method of transmission over the internet, or method of electronic storage, is completely secure. While we apply commercially reasonable measures to safeguard your personal data, we cannot guarantee absolute security. You share your personal data at your own risk. Where we have given you, or where you have chosen, a password to access certain parts of our platform, you are responsible for keeping that password confidential. Do not share your password with anyone. If you believe your personal data has been compromised or that there has been unauthorised access to your account, contact us immediately so we can take appropriate action. 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. Once your personal data is no longer needed, we will securely delete or anonymise it in accordance with our data retention procedures. Where we transfer your personal data outside of New Zealand, we take steps to ensure it receives a comparable level of protection. We only transfer personal data to recipients in jurisdictions that provide adequate protections, or under appropriate contractual safeguards.

We have taken appropriate organisational and technical measures to protect personal data, including against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that personal data will remain secure at all times, nor can we accept liability for indirect, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by legal or regulatory obligations beyond our control, we may be required to disclose personal data to third parties, including public authorities. In such cases, we have no control over how those third parties handle or protect that data.
No method of transmitting data over the internet is completely 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 sites and apps are not operated or supervised by the Company, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through third-party sites or apps.
Before accessing or using any linked third-party website or app, we recommend reading its privacy policy carefully. We also advise using caution when sharing Personal Data with any third party.

12. Changes to This Policy

Before visiting any third-party website or app, read their privacy policy carefully. We also recommend exercising caution when sharing personal data with them.

13. Your rights regarding 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 are not required to retain. You may also request that we 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 provide to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
We can verify that your Personal Data is being processed and, if so, provide you with access to it.
We will supply an electronic copy of your Personal Data currently being processed. A reasonable fee may be charged 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 refuse or limit our response accordingly.
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
You may request erasure of your Personal Data 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 to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) erasure is required 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.
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 rights, to protect the rights of another person, or where there is a substantial 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, 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 does not infringe the rights or freedoms of others.
Right to object
You have the right to object at any time to processing of Personal Data concerning you that 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, freedoms, or interests, we will cease processing.
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
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.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights in relation to your Personal Data as described in this section 13.
We will respond to requests made under section 13 within one month of receipt. Where the complexity or volume of requests requires it, this period may be extended by up to two months. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
Unless otherwise limited under section 13, information provided in response to your rights 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.