Lark Fundmere

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: 10.06.2026

We (referred to as "We", "Us", or "Our") 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 website Lark Fundmere (the "Website").

We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods to keep you informed, and where we believe specific details are relevant to you, we will provide them at the appropriate time. We are happy to answer any questions you may have, subject to any limitations imposed by law.

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

1. The Scope

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

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 combining that information with additional information we hold or can access.

1.3 Under this Policy, "processing" means any operation that uses or collects Personal Data, including its management, structuring, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18, nor do we knowingly permit such persons to use our services. If we become aware that we hold information about a child, we will delete it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access our service and channels or visit our website. In certain cases, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. However, withholding such data may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.1 This includes information about your online activity log and your traffic data, such as:

  • 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 we collect is not personal data 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's 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 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.

5.2 The Company cannot process your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are as follows:

  • You have given consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
  • The Company or a third party may need to process personal data to serve a legitimate interest, such as improving Our Services or defending legal claims.
  • Processing must meet an obligation of law.

5.3 Contact us via email for more details about the processing necessary to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

Scope

Legal Basis

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

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

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

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

To comply with any legal obligation or administrative, judicial, or legal requirement, Personal Data is processed to meet applicable legal requirements.

To ensure compliance with legal obligations, processing is required.

4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports we collect in relation to the Services.

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

5. To stop fraud and misuse of Our Services.

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

6. To perform and manage activities aligned with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.

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

7. To conduct analysis, such as statistical analysis
We apply various analytical techniques, including statistical methods, to make decisions on different issues.

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 Personal Data to protect our rights, interests and assets, or those of a third party, in compliance with any applicable laws, regulations or agreements, and any conditions, terms or policies.

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

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 analysis of user experiences.

6.2 You can also request that we share specific Personal Data about you with third-party trading platforms. Where you ask us to do so, we will provide the Personal Data you have given us to those third-party trading platforms. The use of your Personal Data is then governed by 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 provides the Company with the resources needed to enhance and improve the products and services it offers its customers.

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 your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in connection with such a transaction (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 of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or other 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 the user experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only until 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 make it easier for you to return to the website.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary for you to access the features you request and navigate our website. They are used to provide the information, products, and services you have asked us for.
They are also required for your device to download and stream data, allowing you to move around the website, use its features, and return to pages you have previously visited.

Additional Information

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. These are session Cookies, which are deleted once you close your web browser.

The type of cookie

Functionality Cookies

Scope

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

Additional Information

They remain active until their expiry date and stay saved even after you close your browser.

The type of cookie

Cookies for performance

Scope

We use cookies to collect statistics on the site's performance and to help improve it. They also allow us to analyze how our website is used.

Additional Information

Cookies store anonymous data that is not linked to any identified or identifiable person. Some can be removed when you close your browser, while others remain valid indefinitely.

7.4 Blocking or removing cookies. To prevent or remove cookies, you must adjust your browser's settings. The links below explain the process for some of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please be aware that some or all of the Website's functions and features may not work as you expect if this occurs.

Online Tracking Notice: This service does not currently respond to 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 described in this Policy, or for longer periods 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. If you consent, we will continue to share your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

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

These protections and safeguards are available to all residents of the EEA (European Economic Area):

  • Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for transferred Personal Data, 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 authorities or bodies, in accordance with Article 46(2)(a).
  • The transfer was carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

9.3 The Company can provide details of the security measures used to protect your Personal Data when it is transferred to third-party countries or international organisations. Send an email to: support@lark-fundmere.com

10. Security of Personal Data

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 that the security of your Personal Data will be maintained without error, nor can we be held accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Where legal or other obligations beyond our control require it, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications that operate outside the Company's control. We are not responsible for the collection or processing of Personal Data by these sites or applications. This Policy does not apply to any actions taken through them.

11.2 When you visit any third-party website or app, we recommend reading their privacy policies before deciding to access or use them. We also recommend caution before providing any Personal Data to them.

12. Modifications to This Policy

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

12.2 If we make significant changes to this Policy, we will notify you through methods we consider appropriate and publish an announcement on our website.

12.3 Unless otherwise specified, any amendments take effect once the revised Policy is published.

13. Your Rights

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

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, send an email to the address below.

13.3 Access rights The Company can confirm whether your Personal Data is being processed. If it is, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would harm the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of the processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfil a legal obligation that requires processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Restricting processing If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, your Personal Data may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.

13.7 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 review 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 portability must not adversely affect the rights or freedoms of others.

13.8 Right to object You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing, we will continue only if those grounds override your rights, freedoms, or interests, or where the processing is required for the establishment, exercise, or defense of legal claims. 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 Personal Data about you at any time. This 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 your supervisory authority. 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 regarding Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you request under your rights 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. We will inform you of any extension, and the reasons for it, within one month of receiving your request.

13.11 Unless section 13 of the law provides otherwise, the information you request under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly if it is repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or carrying out the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable proof of identity.

This Privacy Policy should be read together with our Term Of Use and Risk Disclosure.

Lark Fundmere 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@lark-fundmere.com