Privacy Policy

We (“we,” “us,” or “our”) are committed to protecting your personal data and your privacy.

This Privacy Policy explains how we collect and store the information you submit via the Lumen Fundex website (the “Website”).

We will defend these principles:

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

We aim to ensure you can make informed decisions regarding the use and processing of your personal data. This is why we created this website. To that end, we use a range of methods and procedures to provide relevant information about our personal data practices.

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

We are happy to answer any questions and will provide any clarifications you need regarding any limitations set by law. You can reach us by email at the address below: info@lumen-fundex.com

• Personal data 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 to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, complying with legal and regulatory obligations, and performing administrative and business activities to support the provision and use of the Services.

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

• Make use of essential tools to protect and enforce your rights regarding personal data:

To help you exercise your rights, we provide extensive support. Contact Us anytime to request access to your personal data. We can correct or delete it, and restrict or stop its use for specific purposes or overall. We can also transfer your information to you or to a third party. We will make every effort to accommodate your requests.

• Protect your personal data:

While we cannot guarantee the absolute security of your personal data, we remain committed to employing a range of measures and techniques to help ensure it remains protected.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy outlines the types of personal data the company collects about individuals, and how it processes, shares with third parties, secures, and otherwise handles that data.

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 through other information we hold or can access.

The Policy defines “processing” as any activity that involves the use or collection 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 anyone under the age of 18. We do not knowingly collect or solicit information from individuals under 18, nor do we knowingly permit such individuals to use our services. If we become aware of any information about a minor, we will delete it as promptly as possible.

2. What personal data do we hold about you?

If you use our services or channels, or visit our website, we may collect personal data. In some cases, we may ask you to provide it. In others, we collect it by analyzing how you use our services and channels, or by receiving information about you from our third-party partners.

3. No obligation to provide personal information to the Company and the potential consequences.

You are not required to provide us with any personal data. In certain circumstances, you may choose not to share such information. This could prevent us from delivering our services or limit users' access to the website.

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

This includes details about your online activity logs, traffic data (such as IP address and the date and time of access), the language you use, software crash logs, the type of browser used, and information about the device you use. The information collected 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 provide directly to third-party platforms to enable transactions: this includes your full name, address, phone number, and email address.

5. Legal basis and purposes for the processing of personal data

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

Without a lawful basis, the company cannot use personal data about you. 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 through the website so that we can transfer it to a third-party trading platform.
• The Company or third parties may need to process personal data to pursue legitimate interests. This may include improving our services or defending against legal claims.
• Processing must satisfy a legal obligation.

Please contact us by email for more information about processing required to protect legitimate interests.

Below is a list of the reasons and legal bases on which we may use the personal data you provide to us.

6. Transfer of Personal Data to Third Parties

The company may also share personal data with third-party service providers—such as hosting and storage vendors—for processing IP address information and analyzing user experiences.

You may also request that we share certain personal data about you with third-party trading platforms. In such cases, we will transmit the personal data you have provided to us to those third-party platforms. Their use of your personal data will be governed by their own privacy policies. Your personal data may be shared with multiple trading platforms.

The Company may share personal data with its affiliates or business partners. Such sharing can provide the Company with the resources needed to enable it to enhance and improve the products and services it offers to customers.

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

We may also share your personal data with potential investors or buyers, or with lenders to the company or any other group company, 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 services, including advertising partners that serve ads on our website and analytics providers. These companies may also use cookies or other technologies.

Cookies are small text files stored on your device when you visit or use this website. They collect information about your preferences and browsing behavior to enhance your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.

Some of the cookies we use are session cookies. They are temporarily stored on your device and last only while your browser is open, then are deleted when you close it. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. These help the website recognize you as a returning user and make it easier for you 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, you will need to adjust your browser settings. Below are links to guide you through the steps for several of the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

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

ONLINE TRACKING NOTICE

The Company will retain your personal data for as long as necessary to fulfill the processing purposes described in this policy, and may retain it for longer periods as permitted by applicable laws, regulations, policies, and any relevant orders.

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

We routinely review the Personal Data we retain to ensure it is not kept longer than necessary.

9. Cross-border transfers of personal information to third countries or international organizations

Your personal information may be transferred to other countries (for example, to a third country—meaning a country other than the one where you reside), to international organizations, or to other jurisdictions. The Company takes all necessary steps to protect the personal data you provide and ensures 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 European Commission has determined ensures an adequate level of protection for personal data under 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 conducted pursuant to a legally binding, enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a) of the GDPR.
• The transfer was carried out in accordance with the European Commission’s Standard Contractual Clauses adopted under GDPR Article 46(2)(c). The Clauses adopted by the European Commission can be viewed 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 on the security measures it uses to protect your personal data when transferred to third countries or international organizations. To request this information, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organizational and technical measures to protect personal data. These measures include preventing accidental or unlawful destruction, loss, or alteration of personal data.

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

If legal or other obligations beyond our control arise, we may be required to disclose your personal data to third parties, including regulators and public authorities. In such circumstances, we cannot control how those third parties handle and protect your personal data.

No method of transmitting personal data over the internet is entirely secure. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to websites owned or operated by third parties

Our website may provide links to third-party websites and applications. These sites and apps are not operated or controlled by the Company. We are not responsible for the collection or processing of personal data by these third parties. This Policy does not apply to activities conducted on or through such sites or apps.

When visiting any third-party websites or apps, we recommend reading their privacy policies before deciding whether to access or use their services. We also suggest that you provide any personal data directly to them.

12. Changes to This Policy

This Policy may be updated at any time. If we make changes, we will notify you by posting the updated Policy on our website. Additionally, when we implement significant modifications to this Policy, we will attempt to inform you through methods we consider appropriate and will publish a notice on our website. Unless stated otherwise, amendments take effect upon publication of the revised Policy.

13. Your rights regarding your personal information

You are entitled to ask us to verify the accuracy of the personal data we collect about you, correct any errors, and delete any personal data we do not require. You may also limit the scope or types of processing of your personal information.

If you are a resident of the EEA, please refer to this page:

These rights apply to the personal data you provide to us. To exercise your rights, please submit a request by email to the address below.

Access rights

The Company can verify the accuracy of the personal data being processed about you. If they are accurate, you are able 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. Upon request, the data will be made available electronically.

Your right to access personal data must not infringe upon the rights and freedoms of others. If a request would adversely affect another person’s rights or freedoms, the company may refuse to comply or limit the scope of its response.

Right to rectification

The Company has the right to correct inaccurate personal data. You have the right to request that any incomplete personal data about you be corrected, 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 no other legal basis exists for processing; (c) You object at any time, for reasons specific to your situation, to processing based on legitimate interests pursued by us or a third party; (e) Personal data have been processed unlawfully; or (f) Personal data must be erased to comply with the company's legal obligations.

This right does not apply where 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 claims.

Processing restrictions

If you are concerned about the accuracy of your personal data, you may ask the company to limit the processing of your personal data.

If you request that personal data be restricted, personal data may only be retained if you provide consent, or where it is necessary in order to establish, exercise, or defend legal claims, to protect the rights and freedoms of another natural person, or for reasons of significant public interest within 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 a contract to which you are a party, you have the legal right to 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. The right to data portability must not adversely impact the rights and freedoms of others.

Right to challenge

You have the right to object at any time to the processing of personal data concerning you that is based on legitimate interests pursued by us or by a third party. This includes any profiling carried out on that basis. If we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or if the processing is necessary for the establishment, exercise, or defense of legal claims, we may continue the processing; otherwise, we will stop.

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 withdraw your consent for us to process your personal data at any time. This will not affect the lawfulness of processing carried out based on your consent before it was withdrawn.

You have the right to lodge a complaint with the relevant supervisory authority.

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

The laws of the European Union and its Member States may restrict your rights with respect to your personal data, as described in Section 13.

We will provide the requested information in accordance with your rights under Section 13 of this agreement within one month of receiving your request. This timeframe may be extended to up to two months, if necessary, depending on the nature of the request and the volume of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.

Provided it does not conflict with section 13 of the law, information requested 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 administrative costs of providing the information or communicating the requested action. We may also decline to act.

If we have any doubts about the identity of the individual who submitted your request, the company may, in certain cases, request additional information to confirm your identity and protect your account for security purposes.