Privacy Policy

We (referred to as “We”, “Us” or “Our”) are committed to safeguarding your personal data and privacy.

This Privacy Policy has been designed to inform you of the methods we use to collect and store the information you provide through the Sûreté Zenvor website (the “website”).

We will defend these principles:

• To ensure transparency in the collection and processing of your personal information:

We aim to empower you to make informed choices about how your personal data is collected, used, and processed. That’s why we’ve built this website. Through a variety of methods and procedures, we offer clear, relevant information on every aspect of personal data management.

If we determine that you require additional details, we will provide the information at the appropriate date and time

We’re happy to answer any questions you may have and clarify any legal limitations. Please reach out via email at the address below: info@surete-zenvor.com

• Personal data will only be used for the purposes outlined in this policy.

Personal Data may be processed by us for a variety of purposes, such as providing you with access to the website and connecting you with third-party trading platforms (the 'Services'), enhancing and securing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with regulatory or legal obligations, and conducting administrative and business activities to support service delivery and use.

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

• To leverage robust tools designed to safeguard your personal data rights:

To facilitate the exercise of your rights, we have allocated robust resources. You may contact us at any time to request access to your personal data. We will modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a designated third party. We are committed to fulfilling your requests.

• Safeguard your personal data:

Although we cannot guarantee absolute security of your personal data, we will continue to implement diverse methods and techniques to safeguard it.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy outlines the types of personal data the company collects from individuals and how it processes, secures, and shares it with third parties, as well as other related procedures.

This Policy addresses information concerning an identified or identifiable natural person. A natural person is considered identifiable if they can be directly identified, or if their identity can be established through additional information we have, collect, hold, or access.

The Policy defines “processing” as any operation involving the use or gathering of personal data. It includes the management, structuring, and storage of personal data.

Our services are intended for general audiences and are not designed for individuals under the age of 18. We do not knowingly collect any personal information from those under the age of 18, nor do we permit such individuals to use our services. If we become aware that we hold any information about minors, we will delete it as soon as we learn of it.

2. Which personal data do we hold about you?

When you access our services or channels, or visit our website, we collect personal data. Sometimes, we ask you to provide personal information directly. At other times, we gather it by analysing your use of our services or channels, or through data received from third-party partners.

3. You are not required to share personal information with the company, and there are no penalties.

You’re under no obligation to share any personal data with us. However, in certain situations, choosing not to do so may prevent us from providing specific services or users from accessing the website.

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

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

Personal Data We Receive from You: Any personal data you voluntarily provide to us when you connect to an online trading platform operated by a third party through our services.

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

5. Legal basis and reasons for processing personal data

Your personal data is processed by the company for the purposes outlined in this section and in accordance with the applicable legal basis.

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

• You have consented 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 data to meet their legitimate interests. For instance, this may involve improving our services or defending legal claims.
• Processing must comply with legal obligations.

Please email us for more information on the processing required to safeguard our legitimate interests.

Below is a summary of the reasons and legal bases under which we may use the personal data you provide. Personal data.

6. Transfer of Personal Data to Third Parties

The company may also share personal data, including IP addresses, with third-party service providers—such as hosting and storage providers—and with partners that analyze user experiences.

You can also request that we share certain personal data about you with third-party trading platforms. In these cases, we will transmit the personal information you’ve provided to us to the designated trading platforms. Their use of your data is governed by their privacy policies, and your information may be shared with multiple platforms.

The Company may share personal data with related entities or business partners. Doing so can provide the Company with the resources required to enhance and improve the quality of the products and services it provides to its customers.

If necessary to safeguard third parties’ rights or protect assets, The Company is authorized to disclose personal data to regulatory, local or other official authorities.

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

7. Third-Party Cookies and Services

We may engage third-party services, such as website advertisers or analytics firms. These services may also use cookies or other technologies.

Cookies are small text files stored on your device each time you visit or access the website. They gather data on your preferences and browsing habits to improve your user experience, remember your settings, and tailor products and services to your interests. Cookies are also utilized for site statistics and analytics.

Some cookies we use are session cookies, which are temporarily downloaded to your device and expire when you close your browser. Other cookies are persistent, remaining on your device for a period after you close your browser. These cookies help the website recognize you as a returning user and facilitate your return visits.

Types of cookies:

We may use them according to their intended purpose:

Cookies are blocked or have been removed

To block or delete cookies, modify your browser's settings. Below, you'll find links to guide you through the process for several of the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, be aware that some or all of the website's features and functions may not work as expected if this happens.

ONLINE TRACKING NOTICE

The Company will retain your personal data only as long as necessary to fulfill the purposes of data processing described in this policy, or for any longer period permitted by applicable laws, regulations, policies, or orders.

We will share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data for an additional 12 months.

We regularly review the Personal Data we retain to ensure it is no longer needed.

9. Transfers of Personal Information to Third Countries or International Organizations

Your personal information may be transferred or transmitted to other countries—for example, to a third country outside your country of residence—for processing purposes or disclosed to international organizations or made subject to foreign jurisdictions. The Company implements all necessary measures to safeguard the personal data you provide and to ensure that data subjects 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 recognised as providing adequate safeguards for personal data transferred to it 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 made pursuant to a legally enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
• The transfer was conducted in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For information on the security measures we implement to safeguard your personal data when transferring it to third-party countries or international organizations, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented robust organizational and technical measures to safeguard personal data, including protections against accidental or unauthorized destruction, loss, or modification of personal data.

We cannot guarantee error-free security of your personal data. We also cannot be held liable for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, any data disclosed due to transmission errors, unauthorized third-party access, or any other cause beyond our control.

If we are required by law or other unavoidable obligations, we may need to disclose your personal data to third parties, including public authorities. We cannot control how those third parties protect your information in such cases.

Transferring personal data over the Internet is never fully risk-free. The Company cannot ensure the security of any personal data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website provides links to third-party websites and applications. These external platforms are not under the company’s supervision. We are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken on those sites or apps.

Whenever you visit any of the third-party websites or apps we recommend, we encourage you to read their privacy policies before deciding to access or use them. We also recommend that you provide any personal data directly to those parties.

12. Changes to this Policy

This Policy may be modified at any time. When we update it, we will post the revised version on our website, and for substantial changes we will also notify you through appropriate channels and issue an announcement on our site. Unless expressly noted, amendments will become effective upon publication of the updated policy.

13. Your Rights Concerning Your Personal Information

You are entitled to ask us to verify the accuracy of any personal data we collect about you, correct any errors, and delete personal data that we do not need. You may also restrict the categories of processing applied to your personal information.

If you are an EEA resident, please refer to this page:

These rights apply to any personal data you provide under applicable law and are available to you at all times. To exercise any of these rights, please send an email to the address below.

Access rights

The Company can verify that your personal data is being processed accurately. If it is, you are entitled to access your personal data.

The Company will provide an electronic copy of the personal data currently being processed and may charge a reasonable fee for any additional copies. The data will be available electronically upon request.

The right to access personal data must not infringe upon the rights and freedoms of others. If fulfilling a request would harm another individual’s rights or freedoms, the company may refuse or limit compliance with the request.

Right to rectification

The Company may rectify any inaccurate personal data. You have the right to request the correction of any incomplete personal data concerning you, taking into account the purpose of processing.

Right to Erasure

The following reasons apply: (a) Personal data is no longer required for the purpose for which it was 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 you 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 erased to comply with a legal obligation of the company.

This right does not apply if 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 can ask the company to limit its processing.

If you request restriction of your personal data, it will only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights of another individual, or if retention is necessary for a compelling public interest within the European Union or its member states.

Data Portability Rights

If an automated system processes your personal data based on your consent or a contract to which you are a party, you have the legal right to access and review the information you provided to the company.

You have the right to 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 right to erasure. The right to data transfer does not infringe upon the rights or freedoms of any other individual.

Right to challenge

You may object at any time to the processing of your personal data based on the legitimate interests of the company or a third party. This right is not limited to profiling under those interests. If we can demonstrate compelling legitimate grounds for processing, we may continue unless you can show that your rights, freedoms, or interests—or the exercise, establishment, or defense of legal claims—outweigh those grounds.

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

Right to Decline Consent

You may revoke your consent for us to process your personal data at any time. This will not affect the legality or lawfulness of any processing carried out under your consent prior to its revocation.

You have the right to file a complaint with your supervisory authority.

You may file an appeal with the supervisory authority established by an EU member state to protect individuals’ fundamental rights concerning the processing of personal data within the European Union.

European Union and Member State laws may restrict your rights concerning personal data relating to you, as detailed in Section 13.

Within one month of receiving your request, we will provide the information you are entitled to under Section 13 of this agreement. If the nature or volume of requests requires it, this period may be extended by up to two months. In the event of an extension, we will inform you of the additional timeframe and its reasons before the initial one-month deadline.

In accordance with section 13 of the law, we will provide any information you request under your section 13 rights free of charge, unless doing so would conflict with those provisions. If your request is unjustified, excessive, or repeated, we may impose a reasonable fee to cover administrative expenses for providing the information or processing the requested action, or we may decline to proceed.

If we have any doubt concerning the identity of the person submitting your request, the company may ask for additional information.