Larch Vaultmere

TABLE OF CONTENTS

  • 1. The Scope
  • 2. What Personal Data Do We Have on You
  • 3. No Requirement to Disclose Personal Information
  • 4. What Personal Data We Collect
  • 5. Legal Basis and Reasons for Processing of Personal Data
  • 6. Transfer of Personal Data to Third Party
  • 7. Cookies and Services from Third Parties
  • 8. Retention of Personal Data
  • 9. International Transfers
  • 10. Security of Personal Data
  • 11. Hyperlinks to Third Party Websites
  • 12. Modifications to This Policy
  • 13. Your Rights

Privacy Policy

Last updated: 24.06.2026

We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website Larch Vaultmere (the "Website").

We want you to be able to make informed choices about the use and processing of Personal Data. We use various methods and procedures to provide relevant information. If we believe you need specific details, we will provide them at the appropriate date and time. We are happy to answer any questions you may have, subject to any limitations imposed by law.

By using our Website, you acknowledge that you have read and accepted this Privacy Policy. For questions: support@larchvaultmere.com

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects from natural individuals and how it processes, shares with third parties, secures, and otherwise handles it.

1.2 This Policy applies to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we have or can access.

1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data. It includes the handling, organization, and storage of Personal Data.

1.4 Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly collect or seek information from anyone younger than 18 years old. We do not knowingly permit such individuals to use our services. If we become aware of any information relating to children, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 If you access the service and channels or visit our website, we collect Personal Data. We may ask for your Personal Data in certain circumstances.

2.2 In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not required to provide Us with any Personal Data. However, in certain circumstances, you may choose not to provide Us with any Personal Data. This may prevent Us from providing the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.1 This includes details about your online activity log and traffic data, including:

  • IP address
  • Date of access and time of access
  • Language you used
  • Software crash logs
  • Type of browser used
  • Information regarding the device that you utilised

4.2 The information you collect is not personal information and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third-party online trading platform through Us.

4.4 Personal information you provide directly 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 of Personal Data

5.1 Your Personal Data is processed by the company for the purposes outlined in this section and in accordance with the applicable legal basis.

5.2 Without a legal basis, the Company is not able to use Personal Data concerning you. The legal grounds on which the Company is able to process Personal Data regarding you:

  • You have consented to the processing of your Personal Data for one or more reasons. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
  • The Company or a third party may require processing to meet their legitimate interests. For example, this may be necessary to improve Our Services or defend legal claims.
  • Processing must meet an obligation of law.

5.3 Contact us by email for more details about the processing required to protect legitimate interests.

5.4 Below is a list of the reasons and legal grounds for which we may use the information you provide us with:

Scope

Legal Basis

To provide your personal information to third parties at your request to access digital trading
If you request it We may ask for your Personal Data to share it with third-party companies.

You have given your consent to the processing of your Personal Data for one or more reasons.

2. To respond to your requests, questions, or concerns
Personal Data is needed to help address any questions you may have about the Services.

The Company’s legitimate interests or those of a third party need to be processed.

3. To meet any legal, administrative, or judicial obligation, Personal Data is processed to comply with legal requirements.

To ensure compliance with legal obligations, processing is required.

4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash or malfunction reports we collect in connection with the Services.

The Company's legitimate interests or those of a third party need to be processed.

5. To stop fraud and misuse of Our Services.

The Company’s legitimate interests or those of a third party need to be processed.

6. To carry out and manage activities in accordance with the requirements of Our Services
Such activities include back-office functions, business development efforts, strategic decision-making, oversight mechanisms, etc.

The Company’s legitimate interests or those of a third party need to be processed.

7. To carry out analyses, including statistical analysis
To make decisions on various matters, we use different analytical techniques (including statistical methods).

The legitimate interests of the Company or those of a third party must be processed.

8. To protect our assets, rights, and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any terms, conditions, or policies.

The Company’s legitimate interests or those of a third party need to be processed.

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analysis.

6.2 You may also ask us to provide specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you have given Us to those third-party trading platforms. The use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This can provide the Company with the resources it needs to enhance and improve the products and services it offers its customers.

6.4 If it is necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or any other company in the group, if the same transaction occurs (including the transfer or sale of assets belonging to the Company or any other company in the group) or as part of any merger, restructuring, consolidation or bankruptcy involving the Company or any other business in the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, such as those providing advertisements on our website or analytics companies, may be utilized. These companies may also utilize cookies or other technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits to enhance the user experience, remember your preferences, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Certain cookies we use are session cookies. They are temporarily downloaded to your device and remain for a short period before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are used to help the Website identify you as a returning user and allow users to return to the website.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are essential to let you access the features you've requested and navigate our website. They are used to deliver the information, products and services you have asked us for.
They are needed for your device to download and stream data. This allows you to move through the website, use its features, and return to pages you've previously visited.

Additional Information

Cookies collect Personal Data, including your username and the date of your last login, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).

The type of cookie

Functionality Cookies

Scope

Cookies let us recognize you each time you visit our site and save your preferences and settings.

Additional Information

They remain valid until the expiry date and are stored even after the browser has closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical data on the site's performance and help improve it. They also allow Us to analyze our website.

Additional Information

Cookies store anonymous data that is not linked to any identified or identifiable natural person. They can be removed when you close your browser. Other cookies remain valid indefinitely.

7.4 Cookies may be blocked or deleted. To manage or remove cookies, you need to change your browser settings. Below are links to guide you through the process for some of the most commonly used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please note that some or all Website functions and features may not work as you expect if this happens.

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

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing Personal Data, as described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for an additional 12 months.

8.3 We regularly review the Personal Data we retain to ensure it is no longer needed.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country or to international organizations). The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that users can exercise their rights and access effective legal remedies.

These protections and safeguards are available to all residents of the EEA (European Economic Area):

  • Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
  • The transfer is made under a legally binding and enforceable agreement between public entities or authorities in the viro Article 46(2)(a)
  • The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

9.3 The Company may provide information about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to: support@larchvaultmere.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or modification of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. Nor can we be held accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 If required by law or by other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these situations, we cannot control the level of security third parties provide for your Personal Data.

10.4 Personal Data cannot be transferred over the web in a completely secure way. The Company cannot guarantee the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to Third Party Websites

11.1 Links to third-party websites and applications are available on the website. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such websites or apps.

11.2 When you visit any third-party websites or apps, We recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest that you provide them with any Personal Data.

12. Modifications to This Policy

12.1 This Policy may be changed at any time. If we change this Policy, we will notify you by posting the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will try to notify you using the methods we believe are appropriate and will post an announcement on our website.

12.3 Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your Rights

13.1 You are entitled to ask us to confirm the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data not required by Us. You may also restrict the scope of the types of processing of personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights are available to you with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights The Company may verify the accuracy of the Personal Data being processed about you. If so, you are entitled to access your 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. The data will be made available electronically if you request it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to another person’s rights and freedoms or their rights, the Company may refuse to comply with the request or limit its ability to fulfill it.

13.4 Right to rectification The Company has the right to correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, due to a reason specific to your situation, to the processing of your Personal Data based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are processed unlawfully; or (f) Personal Data must be removed to comply with the company's legal obligation. This right does not apply where processing is necessary (a) to fulfill an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, it may only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights of another natural person, or where there is an important public interest within the European Union or a Member State.

13.7 Right to data portability If processing is carried out by an automated system and is based on your consent or on a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You are also entitled to 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 rights under the right of erasure. The right to data portability does not interfere with the rights or freedoms of anyone else.

13.8 Right to challenge You have the right at any time to object to any use of Personal Data concerning you that is based on the legitimate interests pursued by the Company or a third party. This right is not limited to profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing Personal Data, we may continue unless you show that your rights, freedoms, or interests override those grounds, or unless the processing relates to the establishment, exercise, or defense of legal rights. For direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.

13.9 Right to refuse consent You may revoke your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before it was withdrawn. You are entitled to lodge a complaint with the authority that supervises you. You may also file 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. The laws of the European Union and Member States may limit your rights regarding Personal Data concerning you, as described in this section 13.

13.10 We will provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months, if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.

13.11 Provided it does not conflict with the provisions of section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request We may ask the person making the request to provide reasonable proof of their identity.

This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.

Larch Vaultmere 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@larchvaultmere.com