Privacy Policy
We (also referred to as “we”, “us” or “our”) are committed to protecting your personal data and privacy.
This Privacy Policy explains how we collect and store the information you provide on the Summit Luxeron website (the “website”).
These principles will be upheld:
- To be transparent about how we collect and process your personal data:
We want you to be able to make informed choices about how your personal data is used and processed. That's why we created this website. To achieve this, we use a range of methods and processes to provide you with relevant information about the use of personal data.
If we determine that you require specific details, we'll provide the information at the appropriate date and time.
We are happy to answer any questions you may have and can clarify any legal limitations. You can reach us by email at the following address: info@summit-luxeron.com
- We will use personal data solely for the purposes set out in this policy.
Personal Data may be processed by Us for various purposes, including to provide the website and connect you with third-party trading platforms (the 'Services'); to enhance the site; to protect our rights and interests; to maintain and deliver the Services; to comply with legal and regulatory obligations; and to carry out administrative and business activities that support the provision and use of the Services.
We also process personal data to better understand your preferences and needs.
- To access key tools to safeguard your rights concerning personal data:
To help you exercise your rights, we provide comprehensive resources and support. Contact us at any time to request access to your personal data. We can correct or delete it, restrict or stop processing for specific or general purposes, and transfer your information to you or a third party. We will endeavour to accommodate your requests.
- Protect your personal data:
While we cannot guarantee the absolute security of your personal data, we do guarantee that we will continue to implement a wide range of measures and best practices to keep it protected.
Our privacy and security policy has been finalised.
1. The Scope?
This policy explains the types of personal data the company collects about individuals, how it processes and shares it with third parties, how it safeguards it, and related matters.
This Policy is about information that specifically relates to an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly, or indirectly through additional information we hold or are reasonably able to access.
The Policy defines ‘processing’ as any process that involves the use or collection of personal data. This includes the management, organisation and storage of personal data.
Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly collect information from individuals under 18, nor do we knowingly permit such persons to use our services. If we become aware of any information about children, we will delete it as quickly as possible.
2. What personal data do we hold about you?
When you access our services or channels, or visit our website, we collect personal data. We may request your personal data in certain instances. In other cases, we collect personal data by analysing how our services and channels are used or by receiving information from our third-party partners.
3. You are not required to provide personal information to the company; however, there may be consequences.
You are not obliged to provide us with any personal data. However, in certain circumstances, if you choose not to share such information, there may be implications. This may prevent us from delivering some services or could limit users' ability to access the website.
4. What types of personal data can we collect? When you visit our website, we will collect the following personal information:
This includes details of your online activity log, traffic data (such as IP address and the date and time of access), the language you used, software crash logs, the browser type, and information about the device you used. This information is not personal data 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 a third-party online trading platform through Us.
Personal information you provide directly to third-party platforms to facilitate trade: this may include your full name, address, telephone number and email address.
5. Legal basis and purposes for the processing of personal data
Your personal data is processed by our company for the purposes outlined in this section and in accordance with the applicable legal basis.
Without a lawful basis, the company cannot use your personal data. The legal grounds on which the company may process your personal data are:
- You have given your consent to the processing of your personal data for one or more purposes. This applies when you submit personal information via the website so that we can share it with a third-party trading platform.
- The company or a third party may need to process data to pursue legitimate interests. For example, to improve our services or to defend against legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us by email for further information about processing carried out to protect legitimate interests.
Below is a list of reasons and legal bases for how we may use the information you provide to us. Personal data.
To disclose your personal information to third parties upon your request to access digital trading services
If you request it, we may collect your personal data to pass on to third-party companies.
You have consented to the processing of your personal data for one or more purposes.
To address your requests, questions, or concerns, personal data is required to help us answer any enquiries you may have regarding the services.
Processing is necessary to pursue the company’s legitimate interests or those of a third party.
To comply with legal, administrative, and judicial obligations, personal data is processed to meet all applicable legal requirements.
Processing is necessary to comply with legal obligations.
To enhance Our Services, we may use Personal Data. This includes, among other things, crash and malfunction reports that we collect in relation to Our Services.
Processing is necessary for the company's legitimate interests or those of a third party.
To Prevent Fraud and Misuse of Our Services
To perform and manage activities that align with our service requirements, including back-office functions, business development initiatives, strategic decision-making, oversight mechanisms, and other related operations and processes.
The processing is necessary for the legitimate interests of the company or a third party.
We use a broad range of analytical methods, including statistical techniques, to support decision-making across a variety of issues.
Processing is necessary to pursue the legitimate interests of the company or those of a third party.
To protect our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims. We may process personal data to safeguard our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations or agreements, and any relevant terms, conditions or policies.
Processing is required for the legitimate interests pursued by the company or by a third party.
6. Transfer of Personal Data to Third Parties
The company may also share personal data with third-party providers that support our services, including hosting and storage, processing IP address information, and user experience analysis.
You may also ask us to share specific personal data about you with third-party trading platforms. In these instances, we will provide the personal data you have given us to those third-party platforms. Their use of your personal data is subject to their privacy policies. Your personal data may be shared with multiple trading platforms.
The Company may share personal data with affiliated entities or business partners. This can provide the resources needed to enhance and improve the products and services it offers to its customers.
Where 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 your personal data with potential investors, buyers, or lenders to the company or any other company within our group if such a transaction takes place (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
Third-party services, such as advertisers on our website or analytics providers, may be engaged. These companies may also use cookies or similar technologies.
Cookies are small text files stored on your device whenever you visit or access our website. We use them to collect information about your preferences and browsing behaviour to enhance your experience, remember your settings, and tailor the products and services you see. Cookies are also used for statistical reporting, performance monitoring, and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and remain in place only for a short time until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period after you close your browser. They help the website recognise you as a returning user and make it easier for you to come back to the site.
Types of cookies:
We may use them according to their purpose:
Cookies are strictly necessary
These cookies are essential to enable you to access the features you’ve requested and to navigate our website. We use cookies to deliver the information, products and services you’ve asked us for.
They are essential for your device to download and stream data. This enables you to browse the website, utilise its features, and return to pages you’ve visited before.
Cookies collect personal data, including your username and most recent login date, to verify that you are signed in to the site.
They are automatically deleted once you close your web browser (session cookies).
Functionality cookies
Cookies help us recognise you each time you visit our website and enable us to remember your settings and preferences.
They persist until their expiry date and remain stored even after the browser is closed.
Cookies for performance
We use cookies to collect statistical data about the site's performance and to help improve it. They also enable us to conduct analysis on our website
Cookies store anonymised data that is not associated with any identified or identifiable natural person.
These are removed when you close your browser. Other cookies remain valid indefinitely.
Cookies are disabled or deleted
To block or delete cookies, adjust your browser settings. The links below explain how to do this for several widely used browsers.
- firefox
- Microsoft Edge
- Google Chrome
- safari
However, please note that some or all of the website's features and functions may not work as expected if this occurs.
ONLINE TRACKING NOTICE
The Company will retain your personal data for as long as necessary to fulfil the purposes of processing described in this policy, or for longer where permitted by applicable laws, regulations, internal policies, and relevant orders.
We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to confirm it is no longer required.
9. Transfers of personal data to a third country or an international organisation
Your personal information may be transferred to other countries, meaning your personal data may be sent to a third country (a country other than the one in which you reside) or to international organisations or jurisdictions. The Company takes all necessary measures to protect the personal data you provide and to ensure that data subjects can exercise 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 provides an adequate level of protection 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 under a legally binding, enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view the European Commission’s 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 it is transferred to third countries or international organisations. To request this information, please email info@wealthwaydigital.uk
10. Security of Your Personal Data
We have implemented appropriate organisational and technical measures to protect personal data. This includes preventing the accidental or unlawful destruction, loss or alteration of personal data.
We cannot guarantee or warrant that the security of your personal data will be free from error. We are also not responsible for any intangible, incidental or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures of personal data caused by transmission errors, unauthorised access by a third party, or any other circumstances beyond our control.
In circumstances where legal or other obligations beyond our control apply, we may be required to disclose your personal data to third parties, including public authorities. We cannot control how these third parties safeguard your personal data in such cases.
No method of transmitting personal data over the internet is completely 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
Links to third-party websites and applications may be provided on this website. 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 sites or apps. This Policy does not apply to activities conducted on 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 them. We also suggest that you provide any personal data directly to them
12. Amendments to this Policy
This policy may be updated at any time. If we make changes, we will notify you by posting the updated version on our website. In addition, where we make significant changes, we will endeavour to inform you via methods we deem appropriate and will publish an announcement on our website. Unless stated otherwise, amendments take effect once the revised policy is published.
13. Your rights in relation to your personal data
You are entitled to ask us to verify the accuracy of the personal data we collect about you, to rectify any inaccuracies, and to delete any personal data we do not require. You may also restrict the scope of the processing of your personal information.
If you are an EEA resident, please refer to this page for details:
These rights are available to you in relation to the personal data you provide to us. You can exercise them by sending an email request to the address below.
Access rights
The Company can verify whether personal data are being processed about you. If they are, you may 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 made available electronically upon request
The right to access personal data must not infringe upon the rights and freedoms of others. If a request would adversely affect another individual’s rights and freedoms, the company may refuse to comply or limit the scope of its response.
Right to rectification
The Company may 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 the processing.
Right to Erasure
The following grounds apply: (a) personal data are no longer needed for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, for reasons relating to your particular situation, to processing based on legitimate interests pursued by us or a third party; (d) personal data have been processed unlawfully; or (e) 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) for the establishment, exercise or defence of legal claims.
Processing restrictions
If you are concerned about the accuracy of your personal data, you can ask the company to restrict the processing of your personal data.
If you request that personal data be restricted, such data may only be retained with your consent, to establish, exercise or defend legal rights, to protect the rights and freedoms of another natural person, or where there are reasons of significant public interest within the European Union or in a Member State.
Data portability rights
If the processing is carried out by automated means and is based on your consent or on 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 by the company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability must not interfere with the rights or freedoms of others.
Right to challenge
You have the right to object at any time to any use of personal data concerning you that is based on the legitimate interests of the company or a third party. This also applies to profiling carried out solely on the basis of those legitimate interests. We may continue processing only if we can demonstrate compelling legitimate grounds that override your rights, freedoms or interests, or where processing is required for the establishment, exercise or defence of legal claims.
You have the right to object at any time to the processing of your personal data for direct marketing purposes.
Right to decline consent
You may withdraw your consent to our processing of your personal data at any time. This will not affect the lawfulness of any processing carried out based on your consent before its withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may lodge an appeal with a supervisory authority established by a Member State to safeguard individuals' fundamental rights regarding the processing of personal data within the European Union.
The laws of the European Union and its Member States may restrict your rights regarding personal data about you, as set out 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 time frame may be extended to up to two months if necessary, depending on the nature and complexity of your request and the volume of requests we receive. We will notify you within one month of receiving your request if an extension is required and explain the reasons.
Provided this does not conflict with the provisions of section 13 of the law, the information you request under your section 13 rights will be made available free of charge. If a request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also refuse to act.
If we have any doubts about the identity of the person making the request, the company may request further information to verify your identity.