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://sablethriftimance.com (the Sable Thriftimance).
The following principles apply:

We want you to be informed about how your Personal Data is used and processed. We use a range of methods to keep you appropriately informed, and where specific details are relevant to you, we'll provide them at the right time. If you have questions about any legal limitations that apply, we're happy to answer them.

1. The Scope?

This policy describes the personal data Sable Thriftimance 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. A person is considered identifiable if they can be directly identified, or identified through a combination of information we hold or can 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 or channels, or via information received from our third-party partners.

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

You are not required to provide us with personal data. However, choosing not to 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 from you:

This includes information collected automatically when you use our services, such as your online activity log, traffic data (including IP address, access dates and times), language settings, software crash logs, browser type, 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 trade: 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 who assist in delivering our Services may receive your personal data where necessary to fulfil that purpose. Where required by law, regulation, or lawful authority, we may disclose your personal data to the relevant parties. If you have given your consent to such sharing, we may transfer your personal data accordingly. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We take reasonable steps to ensure that any third party receiving your personal data is bound by appropriate confidentiality and data protection obligations consistent with this policy.

We may share 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. Where you instruct us to do so, we will provide your Personal Data to the relevant third-party trading platforms, whose own privacy policies will govern its use. Your Personal Data may be shared with more than one trading platform in this context.
We may share Personal Data with related entities or business partners where doing so supports the development and improvement of our products and services.
We may disclose Personal Data to regulatory, local, or other official authorities where required to protect the rights or assets of third parties.
We may also share 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 transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Third-party cookies and services

We may engage third-party service providers, such as advertising networks and analytics companies, on our website. These providers may also use cookies or similar technologies. Cookies are small text files placed on your device when you visit the website. They are used to gather information about your preferences and browsing habits, improve your experience, and personalise the products and services presented 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, making it easier to access the website on subsequent visits.

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. 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 permitted by applicable law, regulation, or order.
We share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data 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 are committed to protecting your personal data and take reasonable steps to safeguard it from misuse, interference, loss, and unauthorised access, modification, or disclosure. Where we collect personal data, we store it in controlled environments with appropriate technical and organisational security measures in place. Access is restricted to personnel who require it to perform their role, and those individuals are bound by confidentiality obligations. No method of data transmission over the internet or electronic storage is completely secure. While we implement reasonable safeguards, we cannot guarantee the absolute security of your personal data. You provide your information at your own risk. If you become aware of any security concerns or suspect unauthorised access to your personal data, please contact us promptly so we can take appropriate action.

We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards 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, without limitation, disclosure resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by legal or other obligations outside our control, we may be required to disclose Personal Data to third parties, including public authorities. We have no control over the security measures applied to your Personal Data by those third parties in such circumstances.
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. Links 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 third-party sites or apps.
Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also advise caution when providing Personal Data to third parties.

12. Changes to This Policy

Before visiting any third-party website or app, read their privacy policy carefully. We also recommend limiting the personal data you share with them.

13. Your rights regarding your personal information

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 are not required to retain. You may also restrict the types or scope of processing applied to your personal information.
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 submit a written request to the email address below.
Access rights
Where we are processing Personal Data about you, you have the right to access that data. The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for additional copies. Data will be provided electronically upon request.
The right of access must not conflict with the rights and freedoms of others. Where fulfilling 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 correction of inaccurate Personal Data. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose of the processing.
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, on grounds specific to your situation; (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 claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may request that we restrict its processing while accuracy is verified.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, for the protection of the rights of another natural person, 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 party, you have the right to receive your Personal Data in a structured, commonly used format.
You may also 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 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 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 processing.
With respect to 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 withdrawal.
You have the right to lodge a complaint with a supervisory authority. This is 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 set out in section 13.
We will respond to requests made under section 13 within one month of receipt. Where necessary, and depending on the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, together with the reasons for the extension.
Subject to the provisions of section 13, information provided in response to a request under section 13 will be provided free of charge. Where a request is manifestly unfounded or excessive, particularly where requests are repetitive, we may charge a reasonable administrative fee or decline to act on the request.
Where we have reasonable doubts about the identity of the person submitting a request, we may ask for additional information to verify identity before proceeding.