Privacy notice

We ("We", "Us" or "Our") take your privacy and the handling of Personal Data seriously.
This Policy explains how information supplied through the website at https://fathompledgerance.com, known as Fathom Pledgerance, is collected and stored.
Our approach is guided by the following key principles:

We explain how Personal Data is collected and used so you can consider the choices available to you. The Website provides information about these practices and the reasons for them. Where a particular use requires further detail, we will provide it at the relevant stage. You can ask us to clarify how your information is handled, subject to the applicable limits on the information we can provide.

1. The scope?

This Policy explains the Personal Data Fathom Pledgerance collects about individuals, how that information is processed and stored, when it may be shared with other parties, and the safeguards used to protect it.
It covers information relating to an identified or identifiable person. A person may be identifiable from a single piece of information or from a combination of details that we hold or can reasonably access.
In this Policy, "processing" means an operation involving Personal Data, including its collection, use, organisation, management, and storage.
The Services are intended for people aged 18 or over. We do not knowingly request or collect information from anyone under 18, or knowingly permit anyone under 18 to use the Services. If we discover that we hold information about a child, we will take steps to delete it as soon as reasonably possible.

2. What Personal Data Do We Hold About You?

We collect Personal Data when you visit the Website or use the Services and contact channels. In some situations, we ask you to provide information directly. In others, we obtain information from your use of the Website, Services, or contact channels, or receive it from third-party partners.

3. 3. Providing Personal Information Is Optional, but Some Website Features May Still Require It

You are not required to provide Personal Data to Us. However, if information is required for a particular service or feature and you choose not to provide it, we may be unable to provide that service or grant access to the relevant parts of the Website.

4. 4. Personal Data We May Collect: Technical Information and Other Details Obtained When You Visit the Website

Technical and usage information may include activity logs; traffic data, such as your IP address and the date and time of access; language settings; software crash reports; browser type; and details of the device used to access the Website. Some of this information may identify you when combined with other available data.
We also receive Personal Data that you choose to provide when you ask us to connect you with a third-party trading platform through the Website.
Information provided specifically for a trading-platform referral may include your full name, postal address, telephone number and email address, depending on the details you submit.

5. Grounds and Purposes for Processing Your Personal Data

Scope, Transparency

6. Sharing Personal Data with External Parties

The Company may share Personal Data with external businesses that provide services to us. Examples include hosting and storage providers, services that supply IP address information, and providers that help us analyse user experience.
You may also ask us to send specific Personal Data to third-party trading platforms. In that case, we share the information you provide for the referral. Those platforms use it under their own privacy policies, and more than one platform may receive your details. Consider their information-handling practices before requesting a referral.
Personal Data may be shared with related companies or business partners where this supports the development, improvement, or delivery of the Company's products and Services.
We may disclose information to appropriate public bodies where necessary to protect our rights or assets, or the rights or assets of other parties.
Information may also be shared with prospective or actual investors, buyers, lenders, and other relevant parties to a transaction involving the Company or a group company. This can include a sale or transfer of assets, financing, merger, restructuring, consolidation, or insolvency affecting the Company or another business in the same group.

7. Cookies and External Services

The Website may use external services, including advertising and analytics providers. These providers may use cookies or similar technologies as part of the services they provide on this site.
Cookies are small text files stored on your device when you access a website. They can record browsing activity and preferences, help features work, remember your settings, and help tailor content or services. Information from cookies may also be used for statistics and analysis of Website use.
Session cookies are temporary and generally expire when you close your browser. Persistent cookies remain on the device for a longer period after the browser closes. They can help the Website recognise a returning device and remember information or settings from an earlier visit until the cookie expires or is deleted.

Cookie categories:

We may use these cookies for the following purposes:

Online Tracking Notice
This service does not currently act on browser Do Not Track signals.

8. Retention of your personal data

The Company retains Personal Data for as long as necessary for the purposes described in this Policy, or for a longer period where applicable requirements or orders permit this.
We share referral information with third-party trading platforms for 12 months. If you agree, this sharing can continue for a further 12 months after the initial period ends.
We regularly review the Personal Data we retain to assess whether it is still required for those purposes or should be removed.

9. Transfers of Personal Information to Other Countries or International Organisations

10. Personal Data Security

We use organisational and technical safeguards designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and unauthorised access.
No set of measures can provide complete security. To the extent permitted by applicable law, we do not accept responsibility for incidental, consequential, or non-material loss arising from the use or disclosure of Personal Data. This includes disclosure caused by transmission errors, third-party access, or other circumstances outside our control.
Legal requirements or other obligations outside our control may require us to provide Personal Data to external parties, including public bodies. We cannot control how those parties protect information after they receive it, and their own procedures may apply.
Transmitting Personal Data over the internet carries inherent risks. The Company cannot ensure that information you send to Us online will remain secure throughout transmission.

11. Links to Sites Operated by Other Service Providers

The Website may contain links to external websites and applications that the Company does not operate or control. We are not responsible for the way those services collect or process Personal Data, and their activities fall outside the scope of this Policy.
Before accessing a third-party website or application, read its privacy notice and consider how it handles information. Decide for yourself whether to use the service or disclose Personal Data, rather than assuming that this Website's practices apply to it.

12. Changes to This Policy

We may update this Policy as our Website and information-handling practices change. The updated version will be published on the Website, where you can review the current terms before providing further Personal Data.

13. Your Rights Regarding Personal Data and Its Use

You may ask us to confirm whether Personal Data about you is being collected or processed, request correction of inaccurate information, and request deletion of data that is no longer needed. You may also request restrictions on particular types of processing, depending on the relevant grounds and circumstances.
If you live in the European Economic Area (EEA), please consider the rights described below:
These rights relate to the Personal Data you provide and the information held about you. To make a request, contact us by email and explain which right you wish to exercise and what information or action your request concerns.
Access to Personal Data
You may ask the Company to confirm whether it processes Personal Data about you. If it does, you may request access to that information and details relevant to its processing.
The Company can provide an electronic copy of the Personal Data being processed. A reasonable fee may apply if you request additional copies. Where you request electronic access, the information will be made available in that format.
Access must respect the rights and freedoms of other people. If fulfilling a request would adversely affect those interests, the Company may limit the information provided or decline the relevant part of the request, explaining the applicable restriction.
Correcting information
You may request correction of inaccurate Personal Data and completion of incomplete information. The Company will consider the purpose for which the information is processed when assessing what needs to be corrected or added.
Deleting Personal Data
Deletion may be requested where information is no longer needed for its original purpose, you withdraw consent and no other basis remains, an objection to legitimate-interest processing is upheld, processing was unlawful, or deletion is required to meet an applicable obligation. The circumstances of each request determine whether the relevant ground applies.
Exceptions may apply if processing is necessary to meet a legal obligation or to establish, exercise, or defend legal claims. A deletion request does not automatically require removal of information that must be kept for one of these purposes.
Restricting processing
You may ask the Company to restrict processing in the circumstances that apply to your request, including while the accuracy of Personal Data is disputed or a related concern is being assessed.
Where processing is restricted, the information may be retained. Further use normally requires your consent or another permitted ground, such as establishing or defending legal claims, protecting another person's rights, or addressing a substantial public-interest requirement. Restrictions therefore do not always require deletion of the stored data.
Receiving and transferring data
If automated processing is based on your consent or a contract to which you are a party, you may request the Personal Data you supplied in a form that allows you to receive and use it elsewhere.
You may also ask for information to be sent directly to another controller where this is technically feasible. Exercising portability does not remove your right to seek deletion. A transfer must also respect the rights and freedoms of other people whose information may be involved.
Objecting to processing
You may object at any time to processing based on the legitimate interests of the Company or a third party, including profiling carried out on that basis. The Company will assess the objection. Processing may continue where compelling grounds override your interests, rights, and freedoms, or where information is required to establish, exercise, or defend legal claims.
You may object at any time to the use of your Personal Data for direct marketing. This includes processing carried out for that marketing purpose.
Withdrawing your consent
You may withdraw consent to the processing of your Personal Data at any time. Withdrawal applies going forward and does not affect the lawfulness of processing that took place on the basis of consent before it was withdrawn.
Raising a concern or complaint
If you believe your Personal Data has been handled incorrectly, you may raise a complaint through the procedure available in your location. You can also contact us to explain the concern and request information about the handling of your data.
The rights described in section 13 may be subject to limits under the rules applicable to your circumstances. We assess requests with those limits in mind and explain any restriction that affects the response.
We normally provide information requested under section 13 within one month of receiving the request. Depending on its complexity or the number of requests, the response period may be extended by up to two months. We will tell you about an extension and its reasons within the first month.
Requests under section 13 are normally handled without charge. If a request is manifestly unfounded or excessive, particularly where it is repeated, we may charge a reasonable fee reflecting the administrative work involved or decline to act where this is permitted.
Where the identity of the person making a request is uncertain, the Company may ask for reasonable additional information to confirm it before disclosing Personal Data or taking the requested action.