Privacy Policy

Last Updated On
13/03/2025

Introduction

This privacy policy (this “Policy”) sets out how Thrive Trading Group Ltd. (also referred to as “Thrive”, the “Company”, “we”, “us” or “our”) uses, collects, and protects your personal data through your use of this website, including any data you may provide when you register with us sign up for our newsletter or purchase a product or service or otherwise engaging with our platform in any capacity. You can download this Policy here.

Thrive acts as a controller and is responsible for your data, while you use our services and website.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights (paragraph ‎10), you may contact us or the DPO directly, using the information set out in the contact details section (paragraph ‎11).

Notice: This website is not intended for children and we do not knowingly collect data relating to children.

1. The types of personal data we collect from you
  Personal data means any information about an individual from which that person can be identified.
  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you interact with and use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  9. We also collect, use and share Aggregated Data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How your personal data is collected
We use different methods to collect data from and about you, including through:
1. Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  – apply for our products or services
  – create an account on our website;
  – subscribe to our service or publications;
  – request marketing to be sent to you;
  – enter a competition, promotion or survey; or
  – give us feedback or contact us.
2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  i. Technical Data is collected from the following parties:
  – analytics providers;
  – advertising networks; and
  – search information providers.
  ii. Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  iii. Identity and Contact Data is collected from data brokers or aggregators.
  iv. Identity and Contact Data is collected from publicly available sources.

How we use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To register you as a new customer	– Identity – Contact	Performance of a contract with you
To process and deliver your order including: Managing payments, fees and charges; and Collecting and recovering money owed to us	– Identity – Contact – Financial – Transaction – Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; and Dealing with your requests, complaints and queries	– Identity – Contact – Profile – Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
To enable you to partake in a prize draw, competition or complete a survey	– Identity – Contact – Profile – Usage – Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	– Identity – Contact – Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	– Identity – Contact – Profile – Usage – Marketing and Communications – Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	– Technical – Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalized suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	– Identity – Contact – Technical – Usage – Profile – Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or Consent, having obtained your prior consent to receiving direct marketing communications.
To carry out market research through your voluntary participation in surveys	Data depends on the answers you provide	Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

Direct marketing
During the registration process on our website, when your personal data is collected, you will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-Party Marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting Out Marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us on the details provided to you in paragraph ‎

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, updates to our Terms and Conditions, and checking that your contact details are correct.

Use of Cookies
We may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same website, the information you previously provided can be retrieved, so you can easily the features that you customized. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our services or websites you visit.

Disclosures of your personal data
We may share your personal data where necessary with third parties set out below for the purposes set out in the table paragraph ‎4 above and with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

External data storage Your personal data may be stored on secure servers maintained by third-party hosting providers with whom we have entered into contractual agreements. These third-party vendors are responsible for safeguarding the data in compliance with applicable data protection laws and industry security standards. We take appropriate measures to ensure that such providers implement robust security protocols and maintain the confidentiality, integrity, and availability of the stored data.

Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach, where we are legally required to do so.

Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph ‎10 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
1. Request access to your personal data (commonly known as a “subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
5. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
6. Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
7. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  – If you want us to establish the data’s accuracy;
  – Where our use of the data is unlawful but you do not want us to erase it;
  – Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  – You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.2 If you wish to exercise any of the rights outlined above, please contact us using the contact details provided in paragraph ‎11.

10.3 No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

10.4 What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10.5 Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Details If you have any questions about this Policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO or us in the following ways:
1. Email address: [email protected]

Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.