Privacy Policy

We are committed to being transparent about how we collect and handle 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.
If you have any questions or require clarification about any legally imposed limitations, we're happy to help. You can reach us by email at: info@banyanfundholt.com

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

We may process your personal data for a range of purposes, including providing the website and connecting you with third-party trading platforms (the "Services"), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and carrying out administrative and business activities that support the 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 correct or delete it, restrict how we use it, or have it transferred to you or a third party. We will action 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 measures to protect it.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of 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. A person is considered identifiable if they can be recognised directly, or through a combination of 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 aged 18 and over. We do not knowingly collect personal data from, or permit use of our services by, anyone under the age of 18. 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 circumstance, we may ask you to provide it directly, collect it by analysing how our services and channels are used, or receive it from our third-party partners.

You are not required to provide personal information to us. However, if you choose not to, we may be unable to deliver certain services or grant you access to parts of the website.

You are not required to provide us with any personal data. However, choosing not to may prevent us from delivering the 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, traffic data (including IP address, date and time of access), 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

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: - Service providers and business partners who assist us in operating our platform and delivering our services. These third parties are only permitted to process your personal data for the specific purposes we have authorised. - Regulatory authorities, law enforcement agencies, or other government bodies where disclosure is required by applicable law or a lawful order. - Successor entities in the event of a merger, acquisition, or sale of assets, where your personal data may form part of the transferred assets. - Any other third party where you have given your explicit consent to such disclosure. Where your personal data is transferred to a third party, we take reasonable steps to ensure that appropriate safeguards are in place to protect it. Third parties who receive your personal data are required to handle it in accordance with applicable privacy obligations and our data protection standards. We do not sell your personal data to third parties.

We may share your Personal Data with third-party service providers who support our operations, including hosting and storage providers and user experience analytics services. You may also request that we share specific Personal Data with third-party trading platforms. Where you make such a request, we will provide the relevant Personal Data to the nominated platforms. Your Personal Data shared in this way will be subject to those platforms' privacy policies, and may be shared with more than one trading platform. We may share Personal Data with related entities or business partners where doing so supports the development and improvement of our products and services. Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, government, or other competent authorities. We may also share your Personal Data with prospective investors, acquirers, or lenders to the Company or any other entity within our group of companies in connection with a transaction, including the transfer or sale of assets, or any merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

7. Cookies and Third-Party Services We use cookies and third-party services on our website to improve functionality, analyse usage, and deliver a better experience. Some of these services may collect and process your personal data in accordance with their own privacy policies. Third-party services we use may include analytics tools, advertising networks, and embedded content providers. When you visit our website, these services may set cookies on your device or access cookies already stored there. You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Disabling certain cookies may affect the functionality of parts of our website. By continuing to use our website, you consent to the use of cookies and third-party services as described in this section. For more detail on how we handle your personal data, please refer to our Privacy Policy.

We may work with third-party service providers, such as advertising networks and analytics companies, who may also place cookies or similar technologies on your device. Cookies are small text files stored on your device when you visit the website. They are used to remember your preferences, understand your browsing habits, and tailor the products and services presented to you. Cookies are also used for statistical and analytics purposes. Some cookies we use are session cookies — temporary files that are downloaded to your device and deleted when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies allow the website to recognise you as a returning user and help restore your previous session.

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, regulation, or order.
We may share your information with third-party trading platforms for up to 12 months. With your agreement, 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. Security of Personal Data We are committed to protecting your personal data and take reasonable steps to safeguard it from loss, misuse, unauthorised access, disclosure, alteration, and destruction. While we implement appropriate technical and organisational security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you share personal data at your own risk. Where we have provided you with a password or access credentials to any part of our services, you are responsible for keeping those credentials confidential. Do not share them with anyone. If you believe your personal data has been compromised, or if you have any concerns about data security, please contact us promptly using the details provided in this policy.

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 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 your Personal Data to third parties, including public authorities. We cannot control the level of security applied to your Personal Data by those third parties.
Transmitting Personal Data over the internet carries inherent risk. 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 applications 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 applications.
Before accessing or using any third-party website or application, we recommend reading their privacy policy carefully. We also advise caution when deciding whether to provide any personal data to 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. We encourage you to review this Policy periodically to stay informed of any changes. Your continued use of our services after any modifications constitutes your acceptance of the updated Policy.

Before visiting any third-party website or app, read their privacy policy carefully before choosing to access or use it. We also recommend using caution when sharing any personal data with them.

13. Your rights regarding your personal information Depending on your location, you may have certain rights in relation to 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 a copy of it; the right to request correction of any inaccurate or incomplete personal information; the right to request deletion of your personal information, subject to applicable legal requirements; the right to object to or restrict our processing of your personal information in certain circumstances; the right to data portability, where processing is carried out by automated means; the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal; the right to lodge a complaint with the relevant data protection authority in your jurisdiction. 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. Please note that some rights are not absolute and may be subject to limitations. In certain circumstances, we may be unable to fulfil a request — for example, where doing so would conflict with a legal obligation or adversely affect the rights of another person. Where we are unable to comply with a request, we will explain why. Withholding certain personal information may prevent us from delivering our Services or granting you access to the website.

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 request that we restrict the scope or type of processing applied to your personal data.
If you are a resident of the EEA, please refer to this page:
These rights apply to Personal Data you have provided to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
We are able to verify the accuracy of Personal Data being processed about you. Where confirmed, you may access that Personal 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 made available 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
You have the right to have inaccurate Personal Data corrected. 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) 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, based on grounds specific to your situation; (e) Personal Data has been unlawfully processed; or (f) Personal Data must be deleted 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 for the establishment, exercise, or defence of legal claims, or 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 your right to data portability does not affect your right to erasure, and it must not adversely affect 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 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 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 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 individuals' fundamental 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 13 as they relate to Personal Data concerning you.
We will respond to requests made under section 13 within one month of receipt. Where necessary, given 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, along with the reasons for the delay.
Subject to the provisions of section 13, information provided in response to a valid request 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 making a request, we may ask for additional information to confirm