Privacy Policy
We (referred to as "we", "us" or "our") are committed to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://royalvermode.net (the Royal Vermode).
We are guided by the following principles:
We want you to have the information you need to make informed decisions about how your Personal Data is used and processed. We use a range of methods and procedures to provide clear, relevant information. Where we consider that specific details are required, we will provide them at the appropriate time. We are also available to respond to any questions you may have, subject to any limitations under applicable law.
1. The Scope?
This policy explains the types of Personal Data Royal Vermode collects about individuals, as well as how we process, share with third parties, protect, and manage that information.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly when combined with other information we hold or can reasonably access.
In this Policy, "processing" means any operation involving Personal Data, including its collection, use, organisation, structuring, storage, and management.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly request or collect information from anyone under 18, and we do not knowingly permit such persons to use our services. If we become aware that we have collected information about a child, we will delete it as soon as reasonably possible.
2. What personal data do we hold about you?
When you use our services and channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data directly. In other cases, we collect it by analysing your use of our Services or service channels, or by receiving information about you from our third-party partners.
3. You are not required to share personal information with the company, and choosing not to do so will not result in any consequences.
You are not required to provide Us with any Personal Data. However, in some circumstances, if you choose not to do so, We may be unable to provide the Services, or users may not be able to access the website.
4. What personal data do we collect? When you visit our website, we may collect the following personal information:
This includes details from your online activity log, traffic data (such as your IP address, access date and access time), the language you selected, software crash reports, the browser type, and information about the device you used. 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 to us when you connect, through us, to a third-party online trading platform.
Personal information you provide directly to third-party platforms to facilitate trading: this may include your full name, address, telephone number, and email address.
5. Legal basis and reasons for processing personal data
The Company processes your Personal Data for the purposes set out in this section and in line with the applicable legal basis.
The Company may only use Personal Data about you where a valid legal basis exists. The legal grounds on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes, including where you submit personal information through the Website so that we may transfer it to a third-party trading platform.
- The Company or a third party may need to process your data where this is necessary for legitimate interests, such as improving Our Services or defending legal claims.
- Processing is required to comply with a legal obligation.
Contact us by email for more information about any processing carried out to protect legitimate interests.
Below are the purposes and lawful grounds on which we may use the personal data you provide to us.
Scope, Legal Basis
1. To share your personal information with third parties at your request so that you can access digital trading. Where required, we may ask you to provide Personal Data for forwarding to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns, we may need to process your Personal Data so that we can address any queries you have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed where necessary to comply with legal obligations or to respond to administrative, regulatory, or judicial requirements.
Processing is necessary to meet legal obligations.
4. To improve Our Services. We may use Personal Data to improve Our Services, including crash or malfunction reports collected in connection with the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required for the delivery of Our Services, including back-office operations, business development, strategic decision-making, governance and oversight, and related functions.
Processing is necessary for the Company’s legitimate interests or those of a third party.
7. To carry out analyses, including statistical analyses, and to support decision-making on various matters using appropriate analytical techniques.
Processing is necessary for the legitimate interests of the Company or a third party.
8.
To protect our assets, rights and interests, as well as those of third parties, and to establish, exercise or defend legal claims
We may process Personal Data where necessary to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, terms, conditions and policies.
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. Disclosure of Personal Data to Third Parties
The Company may share Personal Data with third-party service providers that support our operations, including hosting and storage providers, IP address processing services, and user experience analytics providers.
You may also request us to share specific Personal Data relating to you with third-party trading platforms. In such cases, we will provide the Personal Data you have given to Us to those third-party trading platforms. Their use of your Personal Data will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners where this is necessary to support, develop, and improve the products and services offered to its customers.
Where it is necessary to protect the rights, property, or interests of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders of the Company or any other company within the group, where this is connected to a relevant transaction, including the sale or transfer of assets of the Company or any other company within the group, or as part of any merger, restructuring, consolidation, or insolvency process involving the Company or any other company within the group.
7. Third-party cookies and services
We may use third-party service providers, such as advertising partners or 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 or use the website. They help collect information about your preferences and browsing activity so that we can improve your user experience, remember your settings, and tailor products and services that may be relevant to you. Cookies may also be used for statistical and analytics purposes.
Some cookies we use may be session cookies. These are temporarily stored on your device and remain active only for a short time, usually until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a set period after you close your browser and help the Website recognise you as a returning user, making it easier for you to use the website again.
Types of Cookies:
We may use them for the following purposes:
1. Strictly necessary cookies
These cookies are essential for accessing the features you have requested and for moving around our website. They help us provide the information, products and services you have asked for.
They are also needed for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you have visited before.
Cookies may collect Personal Data, such as your username and the date of your most recent login, to verify that you are signed in to the site. Session Cookies are deleted when you close your web browser.
2. Functionality Cookies
Cookies help us recognise you whenever you visit our site and remember your preferences.
Session Cookies may store Personal Data, including your username and most recent login date, to verify that you are signed in to the site. They are deleted when you close your web browser.
3. Cookies for performance
We use cookies to collect statistical information about how the site performs and to help us improve it. They also allow us to analyse activity on our website.
Cookies store anonymous data that is not linked to an identified or identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies are blocked or have been removed
To block or delete cookies, update your browser settings. The links below explain how to do this in some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that if this happens, some or all of the Website’s functions and features may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently recognise Do Not Track signals.
8. Retention of your personal data
The Company will retain your Personal Data for as long as necessary to achieve the purposes for which it is processed, as set out in this Policy, or for any longer period allowed under applicable laws, regulations, policies, or lawful orders.
We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to confirm that it is still required.
9. Transfers of personal information to another country or an international organisation
Your personal information may be transferred outside Botswana or your country of residence, including to another jurisdiction or to an international organisation. The Company will take all necessary steps to protect the Personal Data you provide and to ensure that data subjects can exercise their rights and access effective legal remedies.
These safeguards apply where required under applicable data protection laws.
- Transfer to another country or to an international organisation that has been recognised by the relevant authority as providing an adequate level of protection for the Personal Data being transferred.
- The transfer is carried out under an enforceable agreement between public entities or authorities, in line with applicable data protection requirements.
- The transfer was carried out in accordance with recognised data protection safeguards for international transfers of personal information. Further details on the applicable standard contractual safeguards may be obtained from the relevant data protection authority.
The Company can provide details of the safeguards in place to protect your Personal Data when it is transferred to third countries or international organisations. Please send your request by email to info@royalvermode.net
10. Personal Data Security
We have implemented appropriate organisational and technical measures to protect Personal Data, including measures intended to prevent its accidental or unlawful destruction, loss, alteration, or unauthorised disclosure.
However, we cannot guarantee that the security of your Personal Data will always be maintained without failure. We are also not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including, but not limited to, disclosure caused by transmission errors, unauthorised access by a third party, or any other circumstances beyond our reasonable control.
Where required by law or by obligations outside our control, we may be required to disclose your Personal Data to third parties, including public authorities. In such cases, we cannot control the level of security applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Links to third-party websites
The website may contain links to third-party websites and applications. These websites and applications are not controlled or supervised by the Company. We are not responsible for how they collect or process Personal Data, and this Policy does not apply to any activities carried out through them.
Before accessing or using any third-party website or application, we recommend that you read its privacy policy. You should also review it before sharing any Personal Data with them.
12. Changes to this Policy
Before visiting or using any third-party websites or apps, we recommend that you review their privacy policies and carefully consider whether to share any Personal Data with them.
13. Your rights regarding your personal information
You have the right to ask Us to confirm whether Personal Data about you is being collected or processed, to correct any inaccuracies, and to delete any Personal Data that We are not required to keep. You may also ask Us to limit certain types of processing of your Personal Data.
If additional data protection rights apply to you under applicable law, please refer to this page:
These rights apply to the Personal Data you provide to Us. To exercise any of these rights, you may send a request by email to the address provided below.
Access rights
You may ask the Company to confirm whether Personal Data about you is being processed and, where it is, to provide you with access to that Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Where you request the information electronically, it will be provided in electronic form where possible.
Your right of access must not adversely affect the rights and freedoms of others. If fulfilling a request would prejudice another person’s rights or freedoms, the Company may refuse the request or limit the extent to which it can comply.
Right to rectification
You have the right to request the correction of inaccurate Personal Data held by the Company. You may also request that incomplete Personal Data concerning you be completed, taking into account the purpose for which it is processed.
Right to Erasure
This right may apply where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object, for reasons relating to your particular situation, to processing based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been processed unlawfully; or f) the Personal Data must be deleted to comply with a legal obligation applicable to the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under applicable law; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict the processing of that Personal Data.
Where processing is restricted at your request, the Personal Data may only be stored, unless you give consent for further processing, or where processing is necessary to establish, exercise, or defend legal rights, protect the rights of another natural person, or for reasons of substantial public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of any other person.
Right to challenge
You have the right to object at any time to the processing of Personal Data concerning you where the processing is based on legitimate interests pursued by the Company or by a third party. This includes profiling based on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is required to establish, exercise, or defend legal rights, we may continue processing the Personal Data.
In relation to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
Right to refuse consent
You may withdraw your consent to Our processing of Personal Data about you at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.
You have the right to lodge a complaint with the authority responsible for supervising data protection matters in your jurisdiction.
You may lodge a complaint with a competent data protection authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data.
Applicable data protection laws may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.
Unless this is inconsistent with section 13 of the law, information requested under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where it is repetitive, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information.