Privacy Policy

Your personal data and your assets are our top priority. We are fully committed to protecting them.

Dawnbay Sylor collects and stores data essential to your trading activities. The way we collect and store this data is explained in the following Privacy Policy.

Our policy is guided by the following principles:

• With the aim of ensuring full transparency about our processes for collecting and storing your personal data:

Our aim is to ensure you understand how we collect and process all data so that you can make an informed decision. We have clear guidelines and processes for handling data on this website. Our policy sets out the specific methods we use so that you have clear, concrete information on its use. You are in the driver's seat.

We will always provide information promptly if we determine that you need to be informed. Transparency is key for us.

Our trained staff are always available to answer any questions you may have about any aspect of our processes, including our obligations under the laws of United Kingdom. You can contact us at: info@dawnbay-sylor.com

• No other use of personal data is permitted by us except for what is laid out in our Privacy Policy.

We may process personal data for the following purposes, including the necessary functioning of Dawnbay Sylor services and connecting trader-members with third-party trading platforms. It may also be necessary for the maintenance and enhancement of website functions and services, protecting our rights, and meeting regulatory or other legal obligations. Finally, this data may be necessary for the provision of administrative and other business functions related to the Services provided to you, the client.

So that we can provide better services that meet your preferences and needs, Dawnbay Sylor uses personal data.

• In order to be able to use essential tools to protect your personal data and secure your rights in this regard:

At any time you may contact us to access all of your personal data. We can also modify or delete it as needed. Further, we can support requests to transfer that data to you or to a designated third party. We provide this service and support so you can better exercise your rights to both privacy and control.

• Secure your personal data:

Our security systems are of the highest quality, with banking-level measures. Nonetheless, a one hundred percent guarantee is not possible, but we remain committed to continually upgrading our systems to the highest possible level and reinforcing the measures we already have in place.

We have a detailed and comprehensive privacy policy and highest level security systems.

1. The Scope?

Outlined in this policy are our procedures for the collection, processing and sharing of any and all data relating to natural persons.

The terms of our policy relate to all natural persons who are identifiable or already identified. This specifically refers to any natural person who can be identified or has already been identified in relation to data that has been entrusted to us or that we can access and/or combine.

The processing of data, as defined in the Privacy Policy, specifically refers to the storage, management, and organisation of that personal data.

We do not collect, or seek to collect, any information about individuals under the age of 18. Nor do we allow individuals under the age of 18 to use our platform for any purpose. If we discover any user, or any information relating to a person under the age of 18, that information will be deleted immediately.

2. What personal data do we store?

Upon registering with us, we collect necessary personal data to enable you to use our services. When necessary, we may also ask you to provide personal data to prove ownership of an account, for instance. To improve and maintain the highest quality of services, we gather and analyse data related to your use of our platform's services, as well as those of third party partners.

3. You are never obliged to provide the company with your personal data.

While you are not under any obligation to provide us with your data, choosing not to provide such information may lead to restrictions on our provision of services. It may also lead to your use of our platform being restricted.

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

We do not collect data that could be used to identify you personally. We do collect information such as your specific account activity, the IP address used, and the date and time of access. For maintenance, security and support services, we retain system crash reports, browser information, and the type of device used to access your account. We also collect information on the language used by your account.

In terms of personal data collection, we only collect and retain the information that you agree to provide to us when you connect, through us, with a third party trading platform.

The personal data that you have provided to third-party platforms can include the following: full name, address, telephone number, and email address.

5. Why does the company need my personal data and is it legal for them to do so?

The collection, storage, and processing of your personal information by the company is solely for the purposes laid out within the Policy. All the above uses and processing are in accordance with relevant laws in United Kingdom.

The company cannot handle, process or transmit your data except in accordance with the relevant laws in United Kingdom. The following are the legal grounds for doing so:

• You have agreed to allow the company to store and process your personal data. By submitting your data to the company, you also authorise us to transfer it to the appropriate third-party trading platform. You have given your consent to the processing of your personal data for one or more purposes.
• In order to improve services, establish or defend legal claims, and pursue legitimate interests, among other things, the company may be required to store and process your personal data.
• To meet legal obligations, data processing is required.

If you would like to find out more about the data processing that the company is required to carry out, please contact us by email.

Below you will find a list of the specific uses, as well as the legal basis, on which we may process your personal data.

6. Transfer of Personal Data to Third Parties

To store and process IP addresses, conduct user surveys and analysis, and provide other related services, the company may share anonymised personal data with third-party service providers.

At your request, we will share specific personal data you provide with third-party services. In such cases, the use of your data will be governed by those companies' privacy policies. This may include multiple digital trading platforms.

In order to enhance services for our clients and improve our services overall, the company may share personal information with its affiliates and partner companies.

As legally required or to protect the company's rights and assets, as well as those of third-party partners, we may disclose data to appropriate legal or regulatory authorities.

In the event of a critical business transaction such as the sale of the company, pursuit of investment or a loan, the relevant data may be shared in a legal and appropriate manner. This will also include any company merger, restructuring, consolidation or bankruptcy, as per law.

7. Cookies and Third-Party Services

For the purpose of site analytics, and in partnership with advertising firms, cookies and other technologies of a similar nature may be used, in accordance with law and standard practice.

Cookies - small bits of code that are stored on your device when you visit a website - are used to collect information on browsing behaviour, preferences, etc. Their purpose is to personalise and enhance your user experience. They allow us to remember your settings and preferences, and to tailor service offerings to you on this basis. These cookies are also used for site analytics and to gather statistics for strategic planning.

Broadly speaking, there are two types of cookies used on the site. There are session cookies that are only stored for the duration of your session and are deleted when the browser is closed. Others are persistent cookies, which remain stored in your browser even after you end a session. These allow the site to recognise you as a returning visitor and facilitate your use of the site.

Types of cookies:

Cookies may be used as required, according to their intended purpose:

Cookies have been blocked or deleted

If you want to delete or block cookies, you need to do so through your browser's settings. Follow the links below for step-by-step instructions on how to do so with the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some operations and site features from working as intended.

ONLINE TRACKING NOTICE

Your personal data will be stored as long as may be required for operations as described elsewhere in this policy. It may be stored longer based upon local laws, regulations and company policies.

Your personal data will be shared, upon your request and discretion, with third-party trading platforms for a period of 12 months. Upon expiration of those 12 months, and upon your consent, that data will be shared for a further 12 months.

Our operations include the regular review of all personal data to determine whether it is still needed or not.

9. Transfers of personal data to third countries or international organisations

As required for the provision of services and/or for security reasons, personal data may sometimes be transferred to third countries (a country other than your own) and to international organisations using full security protocols. We apply data security protocols at the highest possible level to protect your data and ensure you have access to legal remedies and rights in all cases.

Within the EEA (European Economic Area), all residents benefit from data protection and safeguards.

• Data transfers are always carried out under EU legal jurisdiction and competence, in line with the standard data protection protocols set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”)
• All data transfers between public entities or authorities occur in accordance with Article 46(2). It is a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, governed by Article 46(2)(c) of the GDPR, set the conditions for data transfers and these transfers take place in accordance with them. The Clauses can be found and read at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For more information on the specific security measures used by the company to protect your personal data during third country transfers, please send a request by email to info@wealthwaydigital.uk

10. Personal Data Protection

Personal data is protected by the highest level of technical and organisational means, following gold standard procedures. Such procedures are a powerful way to prevent any data destruction by unlawful or accidental events, as well as loss or alteration of that data.

While we apply the maximum care and gold standard procedures for data protection, as determined in law, it is impossible to guarantee in all circumstances that your personal data will be maintained error free. For that reason, we cannot be held liable in a case where personal data is disclosed, or for damage of an incidental, intangible or consequential nature. This includes circumstances over which we have no control, such as disclosure resulting from errors in transmission, third party unauthorised access, or any other cause of this nature.

In the event of legally enforceable demands from regulators or legal bodies, we may be obliged to share your personal data with those authorities. Once that data is shared under legal compulsion, we cannot control how those bodies handle, store or protect your data.

Anything transmitted over the internet, including personal information, carries some risk of interception and is not one hundred percent secure. Any data transmitted online cannot be guaranteed secure by the Company.

11. Third-party website hyperlinks

On this website you will encounter links to third party applications and websites. Please note that these are not affiliates and are under no control of the company, nor does our privacy policy apply to these companies. They have their own procedures and priorities for the collection and processing of personal data, and we are not responsible for such activities. Use at your own discretion.

Always read the privacy policy of any company or service when you visit their website before providing any personal data. Ensure that their collection, usage and processing policies align with your preferences and priorities. Any data you choose to share should be provided directly to the service provider.

12. Policy Amendments

At any time we reserve the right to update or change our policy. We will provide notifications of changes on the website and through any other appropriate channels. The updated version of the privacy policy will be posted on the website and this revised policy will take effect immediately upon publication, unless stated otherwise.

13. Your personal data rights

You have full control and the final say over the use of any and all personal data, including verifying its accuracy, correcting errors and/or choosing to delete or restrict both the scope and nature of any data processing by us.

On this page, residents of the EEA will find information relevant to them:

Your personal data is protected by the rights described herein. By sending an email to the address below, you may immediately exercise those rights.

Accessing Your Rights

If the personal data you have provided to us is accurate, you may access that data at any time. Any of your personal data that is being processed is accessible to us and therefore verifiable.

You may request your personal data at any time for verification, and it will be provided to you in electronic format. If you request additional copies of your data that is being processed, beyond the one provided to you, a reasonable fee may be charged.

The rights provided by law and the privacy policy may not be used to infringe upon the rights of others. The company reserves the right to refuse access to personal data or to limit access if this would infringe upon the rights and freedoms of others.

Right to Correct Errors

Any errors in your personal data, whether through omission or incorrect details, may be corrected by you or by the Company to ensure it can be processed properly.

Erasure Rights

You have the right to demand deletion of personal data under the following circumstances. 1) If your personal data has been processed without your consent or outside legal boundaries. 2) Upon request to have that data removed, and where the Company has no legal requirement to retain that data. 3) If you no longer agree to nor accept any data processing by us, even if lawful and within our rights and interests or those of a third party provider, and 4) If we are compelled by law to delete your data.

The right to deletion is overridden and superseded by legal obligations imposed by the EU or any member state’s law. Likewise, this applies where data is required for the exercise of or defence against legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal information in a situation in which you feel it contains inaccuracies.

Upon request that your personal data usage is restricted, it will be deleted except under the following conditions: 1) where the force of law within the European Union or any Member State prevents this. 2) With your consent, if required for the purposes of exercising or defending legal claims. 3) To protect the rights of another natural person.

Right to Data Portability

You have the right to access and review any personal data that you have provided, if you consented in whatever manner to its collection and its processing is carried out by automated systems.

You have the right to request that any and all personal data be transferred to another company or organisation, where this is technically possible. This does not affect your right to have your data deleted. It is not permitted if exercising this right would infringe the rights or freedoms of another natural person.

Right to challenge data processing

Regardless of the Company’s right to pursue our legitimate interests, or those of a third party service provider, you have the right to object to processing and request that it cease. This does not apply where there is a pressing legal need to continue the processing, whether to defend against legal claims or to exercise legal claims. In such cases, we may continue processing your personal data.

You may at any time demand that your personal data not be processed for any direct marketing activities.

Right to Withdraw or Decline Consent

You have the right to withdraw your consent to our processing of your personal data at any time and, where possible, with immediate effect. This does not apply retroactively to processing carried out before you withdrew consent.

If you are unhappy for any reason, you have the right to lodge a complaint with any legal, regulatory or other supervisory authority.

If you believe your rights and freedoms have been infringed in relation to the processing of your personal data, European Union Member States have established regulatory and supervisory authorities for this purpose. You may submit a complaint to these authorities at your discretion.

Section 13 explains the situations in which your personal data rights may be restricted by the laws of the European Union or of Member States.

Upon receiving your request about your personal data and its processing, we will provide access to the information you have requested, as described in Section 13 of this policy. We reserve the right to extend this period by up to two months, depending on the volume of requests and the nature of your request. If this is necessary, we will notify you of any extension to the deadline within one month of receiving your request.

Requested information will be provided to you electronically free of charge, except where this conflicts with the law or the provisions in Section 13. We reserve the right to charge a reasonable fee or to refuse a request where it is deemed spurious, excessive, or repetitive.

We reserve the right to request additional proof of identity if there is any reasonable doubt about the person making a request for personal data, for the purposes of data protection and security.