Boulder Sparhaven

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: 27.07.2026

We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy is intended to let you know how we collect and store the information you provide through the website Boulder Sparhaven (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 you with relevant information. If we believe you need specific details, we'll provide them at the appropriate date and time. We are happy to answer any questions you may have regarding any limitations imposed by law.

By using our Website, you confirm you have read and agree to this Privacy Policy. For questions: support@bouldersparhaven.com

1. The Scope

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

1.2 This Policy relates to information about an identified or identifiable natural person. An identifiable natural person can be defined as someone who is directly identifiable or can be identified using additional information we have or can access.

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

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

2. What Personal Data Do We Have on You

2.1 When 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 analysing 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 some circumstances, you may not need 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 of 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 set out in this section, and in line with the applicable legal basis.

5.2 Without a legal basis, the Company cannot use Personal Data relating to you. The legal grounds on which the Company is able to process Personal Data relating to 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 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 safeguard legitimate interests.

5.4 Below is a list of the reasons and legal grounds on 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 gain access to digital trading
If you ask us to, we may request Personal Data from you and forward it to third-party companies.

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

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

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

3. Personal Data is processed to meet any legal, administrative or judicial obligation and 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 reports 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 line with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, etc.

The legitimate interests of the Company or a third party need to be processed.

7. To carry out analysis, such as statistical analysis
To make decisions on different issues, we use a range of analytical techniques (including statistical methods).

The legitimate interests of the Company or those of a third party need to 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 any applicable laws, regulations, agreements, and any conditions, terms or policies.

The legitimate interests of the Company 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 can also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will provide the Personal Data you have given Us to those third-party trading platforms. The use of your Personal Data will be 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 may 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 potential 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 within the group), or as part of any merger, restructuring, consolidation or bankruptcy involving the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 Third-party services, such as those that provide advertising on our website or analytics companies, may be used. These companies may also use 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 improve your 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 there for a short time before you close your browser. Other cookies are persistent cookies. Persistent cookies stay 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 necessary to let you access the features you've requested and navigate our website. Cookies are used to deliver the information, products and services you have asked us for.
They are required for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you've previously visited.

Additional Information

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

The type of cookie

Functionality Cookies

Scope

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

Additional Information

They remain valid until the expiry date and are retained 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 analyse our website.

Additional Information

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

7.4 Cookies may be blocked or removed. To prevent or remove cookies, you’ll 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 of the Website's 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 fulfil the purpose 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'll share your information with third-party trading platforms for a period of 12 months. If you agree, we'll continue sharing your data for another 12 months.

8.3 We regularly review the Personal Data we hold to make sure 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 sent to a third country or to international organisations). The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that users can assert their rights and access effective legal remedies.

These protections and safeguards are available to anyone residing in the EEA (European Economic Area):

  • Transfer to a third country or international organisation that the EU Commission has determined provides adequate security 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 pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
  • The transfer was carried out in line with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

9.3 The Company can provide information on the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please email: support@bouldersparhaven.com

10. Security of Personal Data

10.1 We have taken appropriate organisational 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. We are also not liable 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 legal or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these circumstances, we cannot control the security provided to your Personal Data by those third parties.

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 via the internet.

11. Hyperlinks to Third Party Websites

11.1 The website may include links to third-party sites and applications. These sites 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 those sites or apps.

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

12. Modifications to This Policy

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

12.2 In addition, if we make significant changes to this Policy, we will seek to inform you using the methods we consider appropriate and will publish a notice on our website.

12.3 Unless otherwise expressly stated, any amendments will take effect once the revised Policy is published.

13. Your Rights

13.1 You are entitled to ask us to verify 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 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 in relation to the Personal Data you provide. You may request to exercise your rights by sending an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If it is, you are able 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 ask for it. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights and freedoms of another person or their rights, the Company can refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data relating to you be rectified, 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, for reasons specific to your situation, to the processing of your Personal Data based on legitimate interests pursued 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 obligations. This right does not apply where processing is necessary (a) to comply with a legal obligation 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 can ask the Company to limit the processing of your Personal Data. If you request that Personal Data be restricted, it may only be kept with your consent, or to establish, exercise or defend legal rights, to protect the rights of another natural person, or where there is a reason of significant 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 a contract you are party to, 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 to erasure. The right to data portability does not interfere with the rights or freedoms of any other person.

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 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 establish compelling legitimate grounds for processing Personal Data, we may continue unless you can demonstrate that your rights, freedoms, or interests override those grounds, or where processing is required for the exercise, establishment or defence 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 withdraw 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 lodge an appeal 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 in relation to Personal Data concerning you, as set out in this section 13.

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

13.11 Provided this 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 communicating the action requested. We may also decline to act.

13.12 If we have any 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.

Boulder Sparhaven 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@bouldersparhaven.com