Privacy Policy

We (also referred to as “We”, “Us” or “Our”) are committed to protecting your personal information and privacy.

This Privacy Policy explains how we collect and store the information you provide when using Zenoa Gainluxa (the “website”).

We will uphold these principles:

• To ensure transparency about how we collect and process your personal information:

We want you to be able to make informed decisions about how your personal data is used and processed. That is why we've created this website. To that end, we use a range of methods and procedures to provide clear, relevant information about the use of personal data.

If we determine that you need specific details, we will provide them at the appropriate date and time.

We are available to answer any questions and to clarify any legal limitations. Please email us at: info@zenoa-gainluxa.com

• Personal information will be used solely for the purposes outlined in this policy.

Personal Data may be processed by Us for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'); improving the site; protecting our rights and interests; maintaining and delivering the services; complying with regulatory or legal obligations; and conducting administrative and business activities that support the delivery and use of the services.

We also process personal data to better understand your preferences and needs.

• Use essential tools to protect your personal data rights:

To enable you to exercise your rights, we've dedicated substantial resources. Contact Us at any time to request access to your Personal Data. We will update or delete it, restrict or stop processing for specific purposes or altogether, and transfer the information to you or a third party. We will accommodate your requests.

• Protect your personal information:

Although we cannot guarantee the absolute security of your personal data, we remain committed to continually applying a range of measures and best-practice techniques to keep it protected.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy explains the types of personal data the company collects about natural persons, how it is processed, when it may be shared with third parties, and the security measures used to protect it.

This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, using information we hold or are able to access.

The Policy defines 'processing' as any activity that involves the use or collection of personal data. This includes the management, organisation, and storage of personal data.

Our services are intended for a general audience and are not designed for persons under 18. We do not knowingly collect information from anyone under 18 or permit such individuals to use our services. If we become aware that we have collected information about a child, we will delete it as soon as reasonably practicable.

2. What personal information do we hold about you?

When you use our services and channels, or visit our official website, we collect personal data. In some instances, we will ask you to provide it directly. In others, we collect personal data by analysing how our services and channels are used, or by receiving information from our third-party partners.

3. There is no obligation to provide personal information to the company, and you will be informed of any consequences of not doing so.

You are not required to provide us with personal data. However, if you choose not to share certain information, we may be unable to provide some services, and users may be unable to access the website.

4. What personal data do we collect? When you visit our website, we will collect the following personal information about you:

This includes information from your online activity log and traffic data (including your IP address and the date and time of access), the language you use, software crash logs, the type of browser, and details about the device you use. This information is not personal and cannot be used to identify you.

Personal Data We receive from you: Any personal information you voluntarily provide to Us when you connect to a third-party online trading platform through Us.

Personal information you specifically provide to third-party trading platforms to facilitate trading includes your full name, address, phone number, and email address.

5. Legal basis and purposes for processing personal data

The company processes your personal data for the purposes outlined in this section and in accordance with the applicable legal basis.

Without a lawful basis, the company cannot use your personal data. The legal grounds on which the company may process your personal data are:

• You have provided consent for the processing of your personal data for one or more purposes. This includes when you submit personal information via the official website so that we can transfer it to a third-party trading platform.
• The Company or third parties may need to process your information to pursue their legitimate interests, for example to improve our services or to defend legal claims.
• Processing is necessary to comply with a legal obligation.

For more information about the data processing we undertake to protect our legitimate interests, please contact us via email.

Below is a list of the purposes and legal bases for which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The company may also share personal data, including IP address information, with third-party service providers such as hosting and storage providers, and with partners that provide user experience analytics.

You may also request that we share specific personal data with third-party trading platforms. In such cases, we will provide the personal data you supplied to us to the relevant third-party trading platforms. Their use of your personal data is governed by their own privacy policies. Your personal data may be shared with multiple trading platforms.

The Company may share personal data with related entities or business partners. This provides the resources needed to enhance and improve the products and services it offers to its customers.

When necessary to safeguard the rights of third parties or protect assets, the Company may disclose personal data to regulatory, local, or other official authorities.

We may also share your personal data with potential investors, buyers, or lenders to the company, or with any other company within our group, if such a transaction occurs (including the transfer or sale of assets belonging to the company or any other group company), or as part of any merger, restructuring, consolidation, or bankruptcy of the company or any other business within the group.

7. Cookies and third-party services

We may use third-party service providers, including advertising partners and analytics companies. These providers may also use cookies or similar technologies.

Cookies are small text files stored on your device when you visit or access the website. They help collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and customise the products and services you may find useful. Cookies are also used for statistical and analytics purposes.

Some of the cookies we use are session cookies. They are stored temporarily on your device and expire when you close your browser. Others are persistent cookies. These remain on your device after you close your browser and help the website recognise you as a returning user, making it easier to return to the site.

Types of cookies:

We may use them according to their intended purpose:

Cookies are blocked or have been removed

To block or delete cookies, adjust your browser's settings. The links below show you how in a few popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, please note that some or all of the website's functions and features may not work as expected if this occurs.

ONLINE TRACKING NOTICE

The Company will retain your personal data only for as long as necessary to fulfil the purposes of processing set out in this policy, or for longer where permitted or required by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for a further 12 months.

We regularly assess the Personal Data we retain to confirm it is no longer required.

9. Transfers of personal information to a foreign country or an international organisation

Your personal information may be transferred to other countries (i.e., a third country other than the one in which you reside) or to international organisations or jurisdictions. The Company takes all necessary steps to protect the personal data you provide and ensures that users can assert their rights and access effective legal recourse.

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

• Transfer to a third country or an international organisation that the European Commission has recognised as providing an adequate level of protection for personal data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”).
• The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These Clauses can be viewed on the European Commission’s official website at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

The Company can provide details of the safeguards in place to protect your personal data when it is transferred to third countries or international organisations. To request this information, please email info@wealthwaydigital.uk.

10. Personal Data Security

We have implemented appropriate organisational and technical measures to safeguard personal data, including measures to prevent accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that the security of your personal data will be free from error. We are 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, disclosures resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.

Where we are subject to legal or other obligations beyond our control, we may be required to disclose your personal information to third parties, including public authorities. In these circumstances, we cannot control the measures those third parties use to protect your personal information.

No method of transmitting personal data over the Internet is completely secure. Accordingly, The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications may be available on this website. These sites and apps are not controlled or supervised by the company. We are not responsible for any collection or processing of personal information by those third parties. This Policy does not apply to activities conducted on or through such sites or apps.

When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest reviewing these policies before providing any personal data to them.

12. Changes to this Policy

This Policy may be updated at any time. If we make changes, we will advise you by posting the revised policy on our official website. In addition, for significant modifications, we will attempt to inform you through channels we consider appropriate and will publish a notice on our website. Unless expressly stated otherwise, amendments take effect once the updated policy is published.

13. Your rights in relation to your personal information

You have the right to request that we verify the accuracy of the personal data we hold about you, correct any inaccuracies, and delete any personal data that is not required by us. You may also restrict the types of processing applied to your personal information.

If you are an EEA resident, please visit this page:

You have rights regarding the personal information you provide. To exercise any of these rights, please email us at the address below.

Access rights

The Company is able to verify the accuracy of the personal data it processes about you. Once verified, you may access your personal data.

On request, the Company will provide an electronic copy of the personal data it is currently processing. A reasonable fee may be charged for any additional copies.

The right of access to personal data must not infringe the rights or freedoms of others. Where a request would adversely affect another person’s rights or freedoms, the company may decline the request or limit the scope of its response.

Right to rectification

The Company may correct inaccurate personal data. You have the right to request that any incomplete personal data relating to you be completed or corrected, taking into account the purpose of processing.

Right to Erasure

The following reasons are applicable: (a) Personal data is no longer required for the purposes for which it was collected or processed; (b) You withdraw your consent and there is no other legal basis for processing; (c) You object at any time, on grounds 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 has been processed unlawfully; or (f) Personal data must be deleted to meet the company's legal obligations.

This right does not apply where the 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.

Processing restrictions

If you are concerned about the accuracy of your personal data, you may request that the company restrict the processing of your personal data.

If you request that your personal data be restricted, it may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or where there is a significant public interest recognised by the European Union or a member state.

Right to Data Portability

If processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to access and review the personal data you have provided to the company.

You are entitled to request that your personal data be transferred directly from the company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. This right to transfer data must not infringe the rights or freedoms of others.

Right to challenge

You have the right to object at any time to the processing of your personal data where it is based on the legitimate interests of the company or a third party, including any profiling carried out on that basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims.

Regarding direct marketing, you have the right to object at any time to the processing of your personal data.

Your Right to Refuse Consent

You may withdraw your consent for us to process your personal data at any time. This won't 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 safeguard the fundamental rights of individuals in relation to the processing of personal data within the European Union.

The laws of the European Union and its Member States may restrict your rights regarding your personal data, as explained in this Section 13.

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 necessary, depending on the nature and volume of requests. Within one month of receiving your request, we'll inform you of any extension and the reasons for it.

As long as it does not conflict with section 13 of the law, information you request under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or communicating the action requested. We may also refuse to act.

If we have any doubts about the identity of the person who submitted your request, the company may request further information.