Tréfonange

TABLE DES MATIÈRES

  • 1. Le périmètre
  • 2. Quelles données personnelles détenons-nous sur vous
  • 3. Aucune obligation de divulguer des informations personnelles
  • 4. Quelles données personnelles nous collectons
  • 5. Base juridique et finalités du traitement des données personnelles
  • 6. Transfert des données personnelles à des tiers
  • 7. Cookies et services de tiers
  • 8. Conservation des données personnelles
  • 9. Transferts internationaux
  • 10. Sécurité des données personnelles
  • 11. Liens hypertextes vers des sites web tiers
  • 12. Modifications de cette politique
  • 13. Vos droits

Politique de confidentialité

Dernière mise à jour : 26.06.2026

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

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we provide relevant information through various methods and procedures. When we determine that you need specific details, we will share that information at the appropriate time. We are available to answer any questions you may have regarding the limitations imposed by law.

By using our website, you confirm that you have read and accepted this Privacy Policy. For any questions: support@trephontange.com

1. Le périmètre

1.1 This policy describes the type of Personal Data the Company collects from individuals, as well as how it processes that data, shares it with third parties, secures its processing, and more.

1.2 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 indirectly by cross-referencing additional information we hold or can access.

1.3 The Policy defines "processing" as any operation that uses or collects Personal Data, including the management, 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 the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. Any information relating to children that we discover will be deleted promptly.

2. Quelles données personnelles détenons-nous sur vous

2.1 Nous collectons des Données Personnelles lorsque vous accédez au service et aux canaux, ou lorsque vous visitez notre site web. Dans certains cas, nous pouvons vous les demander directement.

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. Aucune obligation de divulguer des informations personnelles

3.1 You are not required to provide Us with Personal Data. In some cases, however, withholding your Personal Data may prevent Us from delivering our Services or granting you access to the website.

4. Quelles données personnelles nous collectons

4.1 This includes information from your online activity log and your traffic data, in particular:

  • Adresse IP
  • Date d'accès et heure d'accès
  • Langue utilisée
  • Journaux de plantage du logiciel
  • Type de navigateur utilisé
  • Informations relatives à l'appareil que vous avez utilisé

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

4.3 Données personnelles que vous nous communiquez : toutes les données personnelles que vous nous fournissez volontairement lorsque vous vous connectez à une plateforme de trading en ligne tierce par notre intermédiaire.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.

5. Base juridique et finalités du traitement des données personnelles

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

5.2 Without a legal basis, the Company cannot use your personal data. The Company may rely on the following legal grounds to process your personal data:

  • You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Site so that we can transmit it to a third-party trading platform.
  • The Company or a third party may process your personal data to serve their legitimate interests. For example, this is necessary to improve Our Services or to defend legal claims.
  • Le traitement doit répondre à une obligation légale.

5.3 For more details on the processing necessary to safeguard legitimate interests, contact us by email.

5.4 Below are the purposes and legal bases on which we may rely to use the information you provide to us:

Périmètre

Base juridique

1. To share your personal data with third parties at your request to access digital trading
If you request it, we may collect personal data from you to share with third-party companies.

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

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

Processing is necessary for the legitimate interests of the Company or those of a third party.

3. To meet any legal obligation or administrative, judicial, or regulatory requirement, Personal Data is processed in accordance with applicable legal provisions.

This processing is necessary to comply with legal obligations.

4. To improve Our Services
We may use Personal Data to improve Our Services. This includes, among other things, any fault or malfunction reports we collect in connection with the Services.

Processing is necessary for the legitimate interests of the Company or a third party.

5. To prevent fraud and the misuse of Our Services.

Processing is necessary for the legitimate interests of the Company or those of a third party.

6. To carry out and manage activities required by Our Services
These activities include administrative functions, business development, strategic decision-making, control mechanisms, and similar operations.

The legitimate interests of the Company or those of a third party require the processing.

7. To perform analyses, including statistical analyses
We use various analytical techniques, including statistical methods, to inform decisions on a range of matters.

Processing is necessary for the legitimate interests of the Company or those of a third party.

8. To protect our assets, rights and interests, and those of third parties
We may process your personal data to protect our rights, interests and assets, or those of third parties, in compliance with all applicable laws, regulations and agreements, and with any terms, conditions or policies.

Processing is necessary for the legitimate interests of the Company or those of a third party.

6. Transfert des données personnelles à des tiers

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 transmit certain Personal Data concerning you to third-party trading platforms. In such cases, we will provide the third-party trading platforms with the Personal Data you have shared with us. The use of your Personal Data is governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with affiliated entities or business partners. This may provide the Company with the resources needed to develop and improve the products and services it offers to its clients.

6.4 Where 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 Personal Data about you with potential investors or buyers, or with the lenders of the Company or any other group company, should such a transaction take place (including the transfer or sale of assets belonging to the Company or any other group company), or in connection with any merger, restructuring, consolidation, or insolvency of the Company or any other group company.

7. Cookies et services de tiers

7.1 We may use third-party services, such as advertising networks that display ads on our website or analytics providers. These companies may also use cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services that may interest you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are temporarily stored on your device and expire shortly after you close your browser. Others are persistent cookies, which remain on your device for a set period after you close your browser. They help the website recognise you as a returning user and allow you to return to the site.

Le type de cookie

Les cookies sont absolument nécessaires

Périmètre

These cookies are required to access the features you request and to navigate our website. They are used to deliver the information, products, and services you have requested.
They are essential for your device to download and display data, allowing you to browse the site, use its features, and return to pages you have previously viewed.

Informations complémentaires

Cookies collect personal data, such as your username and the date of your last login, to confirm that you are signed in to the site. They are deleted as soon as you close your web browser (session cookies).

Le type de cookie

Cookies de fonctionnalité

Périmètre

Cookies allow us to recognize you on each visit to our site and remember your preferences.

Informations complémentaires

Ils restent valables jusqu'à leur date d'expiration et sont conservés même après la fermeture du navigateur.

Le type de cookie

Cookies de performance

Périmètre

Cookies help us collect statistical data on site performance and improve our website. They also allow us to analyze how our site is used.

Informations complémentaires

Cookies store anonymous data that is not linked to any identified or identifiable individual. Some are deleted when you close your browser, while others remain valid indefinitely.

7.4 Blocking or deleting cookies. To block or delete cookies, adjust your browser settings. The links below explain how to do this on some of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please note that if this occurs, some or all features of the Site may not function as intended.

Online Tracking Notice: This service does not currently respond to "Do Not Track" signals.

8. Conservation des données personnelles

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

8.2 We will share your personal data 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.

8.3 We regularly review the Personal Data we retain to confirm it is still required.

9. Transferts internationaux

9.1 Your personal data may be transferred to other countries, including to a third country or international organizations. The Company takes all necessary measures to protect the personal data you provide and ensures that data users can exercise their rights and access effective legal remedies.

These protections and guarantees are available to all individuals residing in the EEA (European Economic Area):

  • Transfer to a third country or international organization that the European Commission has determined provides an adequate level of protection for the 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 bodies or authorities within the meaning of Article 46(2)(a).
  • The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR.

9.3 The Company can provide information on the security measures it applies to protect your Personal Data transferred to third countries or international organisations. Email: support@trephontange.com

10. Sécurité des données personnelles

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee or ensure that the security of your Personal Data will be maintained without error. Nor can we be held liable for any immaterial, incidental, or indirect damages arising from the use or disclosure of Personal Data. This includes, without limitation, any Personal Data disclosed due to transmission errors, unauthorized access by a third party, or any other cause beyond our control.

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

10.4 Personal Data cannot be transmitted over the web with complete security. The Company cannot guarantee the security of any Personal Data you send to Us via the Internet.

11. Liens hypertextes vers des sites web tiers

11.1 The website contains 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 sites or applications. This Policy does not apply to actions carried out through them.

11.2 Before accessing or using any third-party website or application, we recommend reviewing its privacy policy. We also advise caution before providing it with any Personal Data.

12. Modifications de cette politique

12.1 This Policy may be amended at any time. If we make changes, we will notify you by publishing the updated Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will make reasonable efforts to notify you through means we consider appropriate and will post an announcement on our website.

12.3 Unless explicitly stated otherwise, any changes take effect once the revised Policy is published.

13. Vos droits

13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer need. You may also restrict the types of processing applied to your Personal Data.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in connection with your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access The Company can verify the accuracy of the Personal Data it processes about you. Where applicable, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for any additional copies. If you so request, the data will be made available electronically. The right of access to Personal Data must not conflict with the rights and freedoms of others. If your request infringes the rights and freedoms of another person, the Company may refuse to act on it or limit its scope.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You have the right to request the rectification of any Personal Data concerning you that is incomplete, taking into account the purpose of the processing.

13.5 Right to erasure The following grounds apply: (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 legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be deleted to comply with a legal obligation of the company. This right does not apply where the processing is necessary (a) to comply with an obligation imposed by law that requires the processing under European Union law or the law of a Member State; or (b) to establish, exercise, or defend legal claims.

13.6 Restrictions on processing If you have doubts about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request that Personal Data be restricted, it may be retained only with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of important public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is automated and based on consent or on a contract to which you are a party, you have the legal right to access the Personal Data you have 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 rights under the right to erasure. The right to data transfer does not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to any use of Personal Data concerning you that is based on the legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. Where we can establish compelling legitimate grounds for processing the Personal Data, we may continue to do so only if you cannot demonstrate that your rights, freedoms, or interests, or the exercise, establishment, or defence of legal rights, override those grounds. Regarding direct marketing You have the right, at any time, to object to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with the authority that supervises you. You may bring an action before a supervisory authority established by a Member State to protect the fundamental rights of natural persons with regard to the processing of Personal Data within the European Union. European Union and Member State laws may limit your rights concerning the Personal Data that relates to you, as detailed in this section 13.

13.10 We will provide the information requested under your rights set out 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.

13.11 Unless prohibited by Article 13 of the Act, the information you request under your rights pursuant to Article 13 will be provided free of charge. If a request is unfounded or excessive, in particular where it is repetitive, we may charge a reasonable fee to cover the administrative cost of providing the information or communicating the requested action. We may also decline to act on the request.

13.12 If we have doubts about the true identity of the person who submitted your request, we may ask that person to provide reasonable means of proving their identity.

This privacy policy should be read together with our Conditions d'utilisation and Avertissement sur les risques.

Tréfonange 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@trephontange.com