Privacy Policy

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

This Privacy Policy is intended to inform you about the various ways in which we collect and store the information you provide through the website Surela Tradex (the “website”).

We will defend these principles:

  • To be transparent about our collection and processing of your personal information:

We want you to be able to make informed decisions about how your personal data is collected, used, and processed. That's why we have created this website. To support this goal, we employ a variety of methods and procedures to provide you with clear, relevant information on personal data usage.

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

We are pleased to answer any questions you may have and provide any clarifications you need regarding legal limitations. For further assistance, you can contact us by email at the address below: info@surela-tradex.com

  • Personal data will be used solely for the purposes specified in the 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’), enhancing and maintaining the site, protecting our rights and interests, fulfilling regulatory and legal obligations, and conducting administrative and business activities to support delivery and use of the Services.

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

  • To leverage key tools to protect your personal data rights:

We’ve allocated substantial resources to help you exercise your rights. You can contact us at any time to request access to your personal data. We will modify or delete your information, restrict its use for specific or general purposes, and even transfer it to you or a third party. We are fully prepared to promptly accommodate your requests.

  • Protect your personal data:

While we cannot guarantee absolute security of your personal data, we will continuously employ a variety of methods and techniques to protect 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, shares with third parties, and secures that data.

This Policy concerns information about identified or identifiable natural persons. An identifiable natural person is defined as someone who can be recognised directly or through additional data we hold or have access to.

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

Our services are intended for a general audience and are not designed for individuals under 18 years of age. We do not knowingly collect information from anyone under 18 years of age. We likewise do not knowingly permit such individuals to use our services. If we discover any information about a child, we will delete it promptly.

2. What personal data do we hold about you?

When you use our services and channels or visit our website, we collect personal data. In certain situations, we may request this information directly. Otherwise, we obtain your personal data by analysing how you use our services and channels or by receiving it from our third-party partners.

3. You are not required to disclose personal information to the company, and there will be no consequences.

You are under no obligation to provide personal data. However, in certain circumstances, choosing not to share this information may prevent us from delivering services or may restrict users from accessing the website.

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

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

Personal data we receive from you: any information you voluntarily provide when connecting to a third-party online trading platform through us.

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

5. Legal Basis and Rationale for Personal Data Processing

We process your personal data for the purposes set out in this section and in accordance with the applicable legal basis.

Without a valid legal basis, the company cannot use your personal data. The legal grounds on 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 via the website so we can transfer it to a third-party trading platform.
  • The Company or a third party may need to process data to fulfil their legitimate interests. For example, this may be necessary to improve our services or to defend legal claims.
  • Processing must comply with legal obligations.

Contact us by email for further details on the processing required to safeguard legitimate interests.

Below you will find a list of reasons and legal grounds explaining how and why we use the personal data you provide.

Scope
Legal basis

Provide your personal information to third parties at your request to access digital trading

If you request it, we may collect your personal data and forward it to third-party providers.

You have consented to the processing of your personal data for one or more purposes.

To address your requests, questions or concerns, we require personal data to assist with any enquiries you have about our services.

The company’s legitimate interests, or those of a third party, must be processed.

To satisfy any administrative, judicial or other legal obligations, personal data is processed in accordance with legal requirements.

Processing is necessary to comply with legal obligations.

We may use personal data to enhance our services, including, among other things, crash and malfunction reports we collect in connection with those services.

The company’s legitimate interests, or those of a third party, must be processed.

Preventing Fraud and Misuse of Our Services

The company’s legitimate interests or those of a third party must be processed.

To fulfil our service requirements, we conduct and manage activities including back-office operations, business development, strategic decision-making, oversight mechanisms, and more.

The company’s legitimate interests, along with those of any third party, need to be processed.

To support informed decision-making on various issues, we employ a range of analytical techniques (including statistical evaluations) to conduct thorough analyses.

The company's legitimate interests or those of a third party must be processed.

To protect our assets, rights and interests, and those of third parties, we have developed HTML0 to establish and defend legal claims, authorising the processing of personal data necessary to safeguard these rights, interests and assets on our behalf or that of third parties, in compliance with all applicable laws, regulations, agreements, terms, conditions and policies.

The company’s legitimate interests or the interests of a third party must be processed.

6. Transfer of Personal Data to Third Parties

The company may also share personal data—including IP address information and user experience analyses—with third-party service providers such as hosting and storage vendors.

You can also request that we share specific personal data with third-party trading platforms. In such cases, we will disclose the information you have provided to us to these platforms. Their privacy policies govern how they use your data. Your information may be shared with multiple trading platforms.

The Company may share personal data with affiliated entities or business partners. This enables the Company to access resources required to enhance and improve the products and services it provides to its customers.

If necessary to protect the rights of third parties or assets, The Company may 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 or affiliate in our group of companies, in connection with the same transaction, such as the transfer or sale of assets belonging to the company or any other group entity, 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

Third-party services, such as advertising partners on our website or analytics providers, may be engaged. They may also use cookies or other technologies.

Cookies are small text files placed on your device each time you visit or access the website. They collect information about your browsing habits and preferences to enhance your user experience, remember your settings and tailor products and services to your interests. Cookies also support site statistics and analytics.

We use session cookies, which are temporarily downloaded to your device and expire when you close your browser. Persistent cookies remain on your device for a defined period after you close your browser. These cookies help the website recognise you as a returning user and allow you to return to the site. By distinguishing between these cookie types, we ensure both functionality and a personalised experience.

Types of cookies:

We may use them according to their purpose:

Cookie type

Cookies are absolutely essential

Scope

These cookies are essential for accessing the features you’ve requested and for navigating our website. They allow us to provide the information, products and services you’ve requested.

They are essential for your device to download and stream data. This enables you to browse the website seamlessly, use its features and return to pages you’ve visited before.

Additional Information

Cookies collect personal data, including your username and the date of your last login, to verify that you are logged into the site.

Session cookies are cleared when you close your web browser.

Cookie type

Functionality cookies

Scope

Cookies enable us to recognise you each time you visit our site and remember your preferences.

Additional Information

They remain valid until the expiry date and are retained even after the browser closes.

Cookie type

Cookies for performance

Scope

We use cookies to collect statistical data on our site’s performance and help us enhance it. They also enable us to analyse our website.

Additional Information

Cookies store anonymous data that isn’t linked to any identifiable or recognised natural person.

Some cookies are cleared when you close your browser. Others remain indefinitely.

Cookies have been blocked or removed.

To block or remove cookies, modify your browser settings. Below are links to step-by-step guides for several of the most 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 happens.

ONLINE TRACKING NOTICE

The Company will retain your personal data for as long as is necessary to fulfil the purposes outlined in this policy, or for a longer period if required or permitted by law, regulations, policies or applicable orders.

We’ll share your information with third-party trading platforms for 12 months. If you agree, we’ll continue to share your data for an additional 12 months.

We regularly assess the Personal Data we retain to confirm it is still necessary.

9. Transfers of personal information to overseas jurisdictions or to international organisations

Your personal information may be transferred or transmitted to other countries, including third countries (i.e. countries other than where you reside), to international organisations and to jurisdictions outside your country. The Company takes all necessary steps—such as encryption, contractual safeguards, access controls and secure data handling—to protect the personal data you provide and to ensure that you can assert your 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 European Commission has determined offers adequate protection for 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 pursuant to a legally binding and enforceable agreement between public entities or authorities under viro Article 46(2)(a).
  • The data 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. 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.

The Company can provide details of the security measures it uses to protect your personal data when transferring it to third-party countries or international organisations. Please email info@wealthwaydigital.uk to request this information

10. Protecting Personal Data

We have implemented robust organisational and technical measures to protect personal data. This includes preventing accidental or unlawful destruction, loss or alteration.

We cannot guarantee or warrant that the security of your personal data will be maintained without error. 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 personal data disclosed due to transmission errors, unauthorised third-party access or any other cause beyond our control.

If we face legal or other obligations beyond our control, we may be required to disclose your personal data to third parties, such as public authorities. We cannot guarantee the protection of your personal data once it is in the hands of these third parties.

No method of transferring personal data over the web can be completely secure. Consequently, the Company cannot guarantee the security of personal data you transmit to us over the internet.

11. Hyperlinks to third-party websites

We provide links to third-party websites and applications on our website. These external resources operate independently and are not overseen by the company. We are not responsible for any personal data collection or processing conducted by these sites or apps. This Policy does not apply to activities conducted through those platforms.

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

12. Changes to this Policy

This Policy may be revised at any time. When we update it, we will notify you by posting the new version on our website. For significant revisions, we will also seek to inform you in a timely manner through appropriate channels and publish a prominent notice online. Unless clearly specified otherwise, each amendment takes effect upon publication of the updated policy.

13. Your Rights Regarding Your Personal Information

You have the right to ask us to verify the accuracy of any personal data collected about you, to correct mistakes, and to delete any personal information we no longer require. You may also restrict the categories of processing applied to your personal information.

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

You have the right to access and manage any personal data you provide. To exercise these rights, please submit your request by email to the address below.

Access rights

The Company can verify whether your personal data is being processed. If so, you have the right to access your personal data.

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

The right to access personal data must not infringe upon the rights and freedoms of others. If a request adversely affects another party’s rights or freedoms, the company may refuse to comply with the request or limit its capacity to fulfil it.

Right to rectification

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

Right to Erasure

The following reasons apply: (a) Personal data are no longer necessary for the purposes for which they were collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object, for reasons specific to your situation, to our or a third party’s processing of your personal data based on legitimate interests; (e) Personal data has been processed unlawfully; or (f) Personal data must be erased to fulfil the company’s legal obligations.

This right is not applicable where the processing of personal data is necessary: (a) to fulfil an obligation imposed by law and that is required under European Union or Member State legislation; or (b) to create, exercise or defend legal rights.

Processing restrictions

If you have concerns about the accuracy of your personal data, you may request that the company limit its processing.

If you request that personal data processing be restricted, we may retain the data only with your consent; to establish, exercise, or defend legal rights, including those of another natural person; or for reasons of significant public interest within the European Union or a member state.

Your Right to Data Portability

If the processing is automated and relies on your consent or on a contract to which you are a party, you have a 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. Exercising your right to data portability does not affect your right to erasure. Additionally, the right to data portability does not infringe on anyone else’s rights or freedoms.

Right to challenge

You have the right to object at any time to any processing of your personal data that is based on the legitimate interests pursued by the company or a third party. This objection extends beyond profiling that relies solely on those legitimate interests. However, if we can demonstrate compelling legitimate reasons for processing your data, we will only discontinue processing when you show that your rights, freedoms, or interests outweigh our grounds, or if processing is necessary 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 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 based on your consent prior to its revocation.

You have the right to lodge a complaint with your supervising authority.

You may appeal to the supervisory authority established by a member state to protect individuals’ fundamental rights in relation to the processing of personal data within the European Union.

As detailed in Section 13, the laws of the European Union and its Member States may limit your rights in relation to personal data concerning you.

As stipulated in Section 13 of this agreement, we will supply the requested information within one month of receiving your request. If necessary—depending on the request’s complexity or volume—we may extend this period by up to two months. Should we do so, we will notify you within the initial one-month period of the extension and the reasons for it.

As long as it does not conflict with the provisions of section 13 of the law, any information you request pursuant to your rights under section 13 will be provided free of charge. If a request is unjustified or excessive, particularly if it is repeated, we may impose a reasonable fee to cover the administrative expenses of supplying the information or carrying out the requested action. We also reserve the right to decline to act.

If we have doubts regarding the identity of the person submitting your request, the company may ask for further verification, such as additional information or documentation, to confirm their identity.

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