Privacy Policy

Your personal data and assets are our highest priority. We are fully committed to safeguarding them.

Finlex Zenit collects and retains data necessary for your trading activities. How we collect and store this data is outlined in the Privacy Policy that follows.

The following principles guide our policy:

• To ensure full transparency about how we collect and store your personal data:

Our goal is to make clear how we collect and process your personal data, so you can make fully informed decisions. We follow clear guidelines and processes for handling data on this website. Our policy explains the specific methods we use, giving you transparent, concrete information about how your data is used. You are in control of your choices.

We will always share information promptly whenever we determine you should be informed. Transparency is key to us.

Our trained staff are always available to answer any questions you may have about our processes, including our legal obligations under the laws of Singapore. You can contact us at: info@finlex-zenit.com

• No other use of personal data is permitted by us, except as set out in our Privacy Policy.

We may process personal data for purposes such as ensuring the proper operation of Finlex Zenit services and facilitating connections between trader-members and third-party trading platforms. We may also process data to maintain and enhance website features and services, protect our rights, and comply with regulatory or other legal obligations. Finally, where necessary, we process this data to provide administrative and other business functions related to the Services delivered to you, our client.

To offer better services tailored to your preferences and needs, Finlex Zenit uses personal data.

• To access essential tools that help protect your personal data and uphold your rights:

At any time, you may contact us to access all your personal data. We can also update or delete it as required. In addition, we can facilitate requests to transfer your data to you or an authorised third party. We offer these services to help you exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems are engineered to the highest standards with bank-grade protections. While a 100% guarantee is not possible, we are committed to continuously enhancing our systems to the highest practicable level and strengthening the safeguards we have in place.

We maintain a detailed, comprehensive privacy policy and the highest-level security systems.

1. The Scope?

This policy outlines our procedures for the collection, processing, and sharing of all data relating to natural persons.

Our policy applies to all identifiable natural persons. This includes any individual who can be, or has been, identified through data entrusted to us or data we can access and/or combine.

As defined in the Privacy Policy, data processing specifically refers to the storage, management, and organisation of such personal data.

We do not collect, and do not intend to collect, any information about individuals under 18. We also do not allow individuals under 18 to use our platform for any purpose. If we become aware of any user or data relating to someone under 18, we will delete that information immediately.

2. What personal data do we retain?

Upon registering with us, we collect the personal data necessary to enable your use of our services. Where appropriate, we may also request additional information to verify ownership of your account. To maintain and improve the highest quality of our services, we collect and analyse data on how you use our platform and the services of our third-party partners.

3. You are under no obligation to provide your personal data to the Company.

While you are not obliged to share your data with us, declining to do so may limit our ability to deliver certain services to you. It may also result in restrictions on your access to, or use of, our platform.

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

We do not collect information that personally identifies you. However, we do gather details such as specific account activity, users’ IP addresses, and the dates and times of access. For maintenance, security, and support, we retain system crash reports, browser details, and the type of device used to access your account. We also record the language associated with your account.

Regarding personal data collection, we only collect and retain the information you consent to provide to us when you connect with a third-party trading platform through our service.

The personal data you provide to third-party platforms may include: your full name, address, telephone number, and email address.

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

The collection, storage, and processing of your personal information by the company are solely for the purposes set out in this Policy. All such activities are conducted in accordance with applicable laws in Singapore.

The company will handle, process, or transmit your data only in accordance with applicable laws in Singapore. The legal bases for doing so are as follows:

• You have agreed to allow the company to store and process your personal data. By submitting your data to the company, you authorise us to transfer it to the relevant third-party trading platform. You have also consented to the processing of your personal data for one or more purposes.
• To improve its services, establish or defend legal claims, and pursue legitimate interests, among other purposes, the company may be required to store and process your personal data.
• Data processing is necessary to comply with legal obligations.

If you wish to learn more about the data processing the company is required to undertake, please contact us via email.

Below is a list of specific purposes and the corresponding legal bases for which we may process your personal data.

6. Sharing of Personal Data with Third Parties

For the storage and processing of IP addresses, the conduct of user surveys and analysis, and other related services, the company may share anonymised personal data with third-party service providers.

At your request, we will share certain 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.

To enhance the services we provide to our clients and improve overall quality, the company may share personal data with its affiliates and partner organisations.

Where required by law, or to protect the company's rights and assets and those of third-party partners, we may disclose data to relevant legal or regulatory authorities.

For critical business transactions such as a company sale, investment, or loan, relevant data may be shared in a lawful and appropriate manner. This also applies in the event of a merger, restructuring, consolidation, or bankruptcy, in accordance with the law.

7. Use of Cookies and Third-Party Services

We may use cookies and similar technologies for site analytics and, in partnership with advertising firms, in accordance with applicable laws and industry standards.

Cookies—small data files stored on your device when you visit a website—collect information such as your browsing behaviour and preferences. They are used to personalise and enhance your user experience, allowing us to remember your settings and tailor our services accordingly. 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. Session cookies are stored in your browser only for the duration of your visit and are deleted when you close the browser. The others are persistent cookies, which remain stored in your browser even after your session ends. These help the site recognise you as a returning visitor and make it easier for you to use the site.

Types of cookies:

Cookies may be used as necessary, in line with their intended purpose:

Cookies have been disabled or cleared

If you wish to delete cookies or prevent them from being set, this must be done through your browser settings. Follow the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies may disrupt some operations and prevent certain site features from working as intended.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to carry out the operations described in this policy. It may be kept longer to comply with applicable local laws, regulations, and company policies.

Your personal data will be shared, at your request and discretion, with third-party trading platforms for 12 months. Upon expiry of that 12-month period, and with your consent, the 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 required.

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

Where necessary to deliver our services and/or for security reasons, we may transfer personal data to overseas jurisdictions (countries other than your own) and to international organisations, using robust security measures. We apply data security standards at the highest practicable level to safeguard your information and to ensure you retain access to legal remedies and rights in all circumstances.

In the EEA (European Economic Area), all residents are subject to data protection laws and safeguards.

• All data transfers are carried out under EU legal jurisdiction and competence, in line with the data protection requirements 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 are conducted in accordance with Article 46(2). This constitutes a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, issued under Article 46(2)(c) of the GDPR, set the conditions for data transfers, which are carried out accordingly. You can review the Clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

To learn more about the specific security measures the company uses to protect your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is protected using the highest level of technical and organisational safeguards, in line with gold-standard procedures. These measures are designed to prevent unlawful or accidental destruction of data, as well as any loss or alteration

While we exercise the highest level of care and adhere to applicable legal and industry best-practice standards for data protection, it is not possible to guarantee in all circumstances that your personal data will remain free from error. Accordingly, we cannot be held liable if personal data is disclosed, or suffers incidental, intangible, or consequential harm. This extends to situations beyond our control, including disclosures arising from transmission errors, unauthorised access by third parties, system failures, or other similar causes.

If we receive a legally binding request from regulators or legal authorities, we may be required to disclose your personal data to those authorities. Once disclosed under legal compulsion, we cannot control how those bodies handle, store, or protect your data.

Anything sent over the internet, including personal information, carries a risk of interception and is not 100% secure. The Company cannot guarantee the security of any data transmitted online.

11. Hyperlinks to third-party websites

On this site, you may find links to third-party applications and websites. Please note that these are not affiliated with, nor controlled by, the company, and our privacy policy does not apply to them. They maintain their own policies and practices for collecting and processing personal data, and we are not responsible for their actions. Please use them at your own discretion.

Always review the privacy policy of any company or service when visiting their website before sharing any personal data. Ensure their data collection, usage, and processing practices align with your preferences and priorities. If you choose to share data, do so directly with the service provider.

12. Policy Amendments

We reserve the right to update or amend this policy at any time. We will notify you of any changes via our website and other appropriate channels. The updated privacy policy will be posted on the website and will take effect immediately upon publication, unless stated otherwise.

13. Your Personal Data Rights

You retain full control and the final decision over how your personal data is used, including the right to verify its accuracy, correct errors, and choose to delete it or limit the scope and nature of our processing.

This page contains information relevant to EEA residents:

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

Accessing Your Rights

If the personal data you have provided to us is accurate, you may access it 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 we will provide it to you in electronic format. If you request additional copies of the personal data we process, beyond the initial copy provided, a reasonable fee may be charged.

Rights under the law and this Privacy Policy must not infringe the rights of others. The company reserves the right, as permitted by law, to refuse or restrict access to personal data if providing such access would infringe the rights or freedoms of others.

Right to Rectify Errors

Any errors in your personal data, whether due to omissions or inaccurate details, may be corrected by you or the Company to ensure proper processing.

Erasure Rights

You have the right to request the deletion of your personal data in the following situations. 1) If your personal data has been processed without your consent or in breach of legal requirements. 2) Upon your request where the Company has no legal obligation to retain that data. 3) If you no longer consent to any processing by us, even if lawful and within our or a third-party provider’s legitimate interests. 4) If we are required by law to delete your data.

The right to erasure is subject to and may be overridden by legal obligations under EU or member state law. Likewise, when data is necessary for the establishment, exercise, or defence of legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal data if, in certain circumstances, you believe it contains inaccuracies.

Upon your request to restrict the use of your personal data, it will be deleted except in the following situations: 1) where the law of the European Union or any Member State prevents deletion. 2) With your consent, where necessary to establish, exercise, or defend legal claims. 3) To protect the rights of another natural person.

Your Right to Data Portability

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

You have the right to request that any or all of your personal data be transferred to another company or organisation, where technically feasible. This does not affect your right to have your data deleted. This right cannot be exercised if doing so would infringe the rights or freedoms of another individual.

Right to contest data processing

Notwithstanding the Company’s right to pursue its legitimate interests, or those of a third-party service provider, you have the right to object to processing and request that it stop. This does not apply where there is a compelling legal basis to continue processing, including to establish, exercise, or defend legal claims. In such cases, we may continue processing your personal data.

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

Right to Decline or Withdraw Consent

Where feasible, you may withdraw your consent to our processing of your personal data at any time with immediate effect. This does not apply retroactively to processing carried out before your withdrawal.

If you are dissatisfied for any reason, you may lodge a complaint with any legal, regulatory, or other supervisory authority.

If you believe your rights and freedoms have been violated in relation to the processing of your personal data, EU Member States have designated regulatory and supervisory authorities to address such concerns. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines circumstances where your personal data rights may be limited under European Union law or the laws of its Member States.

Once we receive your request concerning your personal data and its processing, we will provide access to the information you requested, as outlined in Section 13 of this policy. We may extend this timeframe by up to two months, depending on the volume of requests and the nature of your request. If an extension is required, we will notify you of the revised deadline within one month of receiving your request.

We will provide requested information electronically at no charge, unless doing so would breach applicable law or the provisions of Section 13. We may charge a reasonable fee or decline requests that are frivolous, excessive, or repetitive.

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