Privacy Policy

We are committed to being transparent about how we collect and process your personal information:

We want you to have the information you need 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 in a clear and relevant way.
Where specific details are required, we will provide them at the appropriate time.
If you have any questions or need clarification about how we handle your Personal Data, including any applicable legal limitations, you can reach us by email at: info@sablewardpartners.com

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

We process your personal data for the following purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site; to protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities required to facilitate your use of the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights with respect to your Personal Data, you have access to the following tools:

To exercise your rights over your personal data, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict or stop its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request.

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 techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of personal data the Company collects from natural individuals, how that data is processed, shared with third parties, and secured.
This policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly or through a combination of additional information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its management, organization, and storage.
Our services are intended for general audiences and are not designed for individuals under the age of 18. We do not knowingly solicit or collect information from anyone under 18, and we do not knowingly permit such individuals to use our services. Any information we discover to have been collected from a minor will be deleted promptly upon discovery.

2. What Personal Data Do We Have on You?

When you access our services, service channels, or website, we collect personal data. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our services or channels, or via information received from our third-party partners.

You are not required to provide personal information to the company. However, choosing not to do so may affect the company's ability to deliver its services or grant you access to the website.

Providing personal data is optional. However, choosing not to share certain personal data may limit our ability to deliver the Services or restrict 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 collected automatically when you visit our platform, such as your IP address, access date and time, browser type, language settings, software crash logs, 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 We process your personal data only where a valid legal basis exists. The specific basis depends on the nature of the data and the purpose for which it is processed. We rely on the following legal bases: Your consent — where you have provided clear, informed consent for a specific processing activity. You may withdraw consent at any time, though withdrawal does not affect the lawfulness of processing carried out before that point. Contractual necessity — where processing is required to enter into or perform a contract with you, including delivering our Services. Legal obligation — where processing is necessary for us to comply with a legal or regulatory requirement. Legitimate interests — where processing serves our legitimate business interests, provided those interests are not overridden by your rights and freedoms. The purposes for which we process your personal data include, but are not limited to: account registration and management, identity verification, service delivery, fraud prevention, security monitoring, customer support, and compliance with applicable legal obligations. Where processing is based on consent or contractual necessity, failure to provide the required personal data may prevent us from delivering our Services or granting you access to the website. We do not process personal data for purposes incompatible with those for which it was originally collected, unless permitted by law or with your consent.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: Service Providers: We engage third-party service providers to support the operation of our platform. These providers may access your personal data only to the extent necessary to perform their contracted services and are bound by confidentiality obligations. Legal and Regulatory Obligations: We may disclose your personal data to regulatory authorities, law enforcement agencies, or other government bodies where required by applicable law or in response to a valid legal request. Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We will notify you of any such transfer and any resulting changes to this policy. Third-Party Partners: Where you have provided consent, or where we have a legitimate interest in doing so, we may share your personal data with selected third-party partners for purposes consistent with this policy. All third parties with whom we share personal data are required to handle it in accordance with applicable privacy laws and to implement appropriate security measures. We do not sell your personal data to third parties. Where personal data is transferred outside of Canada, we take reasonable steps to ensure it receives an equivalent level of protection as required under applicable Canadian privacy legislation.

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. At your request, we may share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be provided to those platforms as requested. Your Personal Data shared with third-party trading platforms is governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform. We may share Personal Data with affiliated entities or business partners to support the development and improvement of our products and services. We may disclose Personal Data to regulatory, governmental, or other official authorities where necessary to protect the rights or assets of third parties. We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within our group — in connection with any proposed or completed transaction, including an asset transfer or sale, 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. These third parties may collect and process your personal data in accordance with their own privacy policies. By continuing to use our website, you acknowledge and accept that such data may be processed by these third parties outside of our direct control. Third-party services we use may include analytics tools, advertising networks, and social media integrations. Each third party operates under its own terms and privacy practices. We recommend reviewing the privacy policies of any third-party services you interact with through our website. You can manage or disable cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of some features on our website.

We may work with third-party service providers, including advertising networks and analytics companies, that operate on our website. These third parties may also use cookies or similar tracking technologies.
Cookies are small text files placed on your device when you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor the products and services presented to you. Cookies are also used for statistical and analytics purposes.
We use two types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device after your browser is closed and are used to recognize you as a returning user, allowing the website to 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 fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.
We share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We periodically review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Information to a Third-Party Country or International Organisation Where personal information is transferred to a third-party country or international organisation, we apply appropriate safeguards to protect that information in accordance with applicable privacy requirements. Any such transfers are conducted only where necessary and under conditions that maintain a comparable level of protection to that provided in Canada.

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organizational measures to safeguard it against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure. While we apply commercially reasonable safeguards, we cannot guarantee absolute security of your personal data. You are responsible for maintaining the confidentiality of any credentials used to access our Services. Notify us promptly if you suspect any unauthorized access to your account or personal data. Where we have engaged third-party service providers to process personal data on our behalf, we require them to implement appropriate security measures consistent with this policy. In the event of a personal data breach that poses a risk to your rights, we will take steps in accordance with our legal obligations, which may include notifying affected individuals and relevant authorities where required.

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards 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, disclosure resulting from transmission errors, unauthorized 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 Personal Data to third parties, including public authorities. We cannot control the level of security applied to your Personal Data by such third parties.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website may contain links to third-party websites and applications. These sites and apps are not operated or supervised by the Company, 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 apps.
Before accessing or using any linked third-party website or app, we recommend reviewing its privacy policy. We also advise exercising caution before providing any Personal Data to third parties.

12. Modifications to this Policy We may update this Policy from time to time. When we do, we will revise the effective date shown at the top of this page. If changes are material, we will provide notice as required by applicable law. Continued use of our services after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of any changes.

Before visiting any third-party website or app, review their privacy policy. Only provide your personal data once you are satisfied with how it will be handled.

13. Your Rights Regarding Your Personal Information You have the following rights in relation to your personal information: Right of access: You may request a copy of the personal information we hold about you and details of how we use it. If you believe we hold any inaccurate personal information about you, you may also request that it be corrected. Right to erasure: In certain circumstances, you may request that we delete the personal information we hold about you. We will comply with such requests unless we have a legitimate reason to retain the information. Right to restrict processing: In certain circumstances, you may request that we limit how we use your personal information. Right to data portability: In certain circumstances, you may request a copy of personal information you have provided to us in a structured, commonly used, machine-readable format. Right to object: Where we rely on our legitimate interests as the legal basis for processing your personal information, you have the right to object to that use. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for the establishment, exercise, or defence of legal claims. Right to withdraw consent: Where we rely on your consent as the legal basis for processing your personal information, you may withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within a reasonable time. Please note that some rights are not absolute and may be subject to applicable legal requirements and exceptions.

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 limit the scope or types of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the 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 can verify whether your Personal Data is being processed. If it is, you may request access to that data.
We will provide an electronic copy of the Personal Data currently being processed. A reasonable fee may be charged for additional copies. Data will be provided in electronic format upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If fulfilling 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 request correction of inaccurate Personal Data. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose of processing.
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 no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) Personal Data is 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 rights.
Right to Restriction of Processing
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 rights, or to protect the rights of another individual, or where there is a significant 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 format.
You may request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not override 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. If we cannot demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or that relate to the establishment, exercise, or defence of legal rights, 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 withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may submit a complaint to 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.
European Union and Member State law may limit the rights described in this section 13 as they relate to your Personal Data.
We will respond to requests submitted under section 13 within one month of receipt. Where necessary, and depending on 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.
Unless otherwise provided under section 13, information provided in response to a request under section 13 will be supplied free of charge. Where a request is manifestly unfounded or excessive, or where requests are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person submitting a request, we may request additional information to verify identity before proceeding.