Privacy Policy

We (also referred to as “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 provide via the Fairholt Flowdex website (the “website”).

These principles will be upheld:

• To ensure transparency about how we collect and process your personal information:

We want you to be able to make informed decisions about how your personal data is used and processed. That's why we created this website. To support this, we use a range of methods and processes to provide you with clear, relevant information about the use of personal data.

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

We are happy to answer any questions you may have and can provide any clarification you require regarding legal limitations. Contact us by email at: info@fairholt-flowdex.com

• Personal data will be used solely for the purposes set out in this policy.

Personal Data may be processed by Us for a range of purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, meeting legal or regulatory obligations, and conducting administrative and business activities to support the delivery and use of the Services.

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

• To access essential tools and resources to protect your rights regarding personal data:

To help you exercise your rights, we have dedicated resources in place. Contact us at any time to request access to your personal data. We can correct or delete it, restrict its use for specific purposes or generally, and transfer it 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 remain committed to continually employing a range of measures and techniques to keep your personal data protected.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy explains the types of personal data the company collects about natural persons and how it processes it, shares it with third parties, and safeguards it.

This Policy concerns information that relates to an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly, or indirectly through a combination of additional information that we hold or are reasonably able to access.

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

Our services are intended for general audiences and are not suitable for anyone under 18. We do not knowingly collect or request information from individuals under 18 years of age, nor do we knowingly permit them to use our services. If we become aware that we have collected information about a child, we will delete it as promptly as possible.

2. What personal data do we hold about you?

When you use our services or channels, or visit our website, we collect personal data. We may request your personal data in certain circumstances. We also obtain personal data by analysing how our services and channels are used, or by receiving information from our third-party partners.

3. No obligation to provide personal information to the company and associated consequences.

You are not obliged to provide us with any personal data. However, in certain circumstances, if you choose not to do so, we may be unable to provide our services. This could also prevent users from accessing 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 logs and traffic data (including your 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 we collect is not personal information and cannot be used to identify you.

Personal data we receive from you: Any personal data you choose to 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 trading: this information includes your full name, address, telephone number, and email address.

5. Legal basis and reasons for processing personal data

The company processes your personal data for the purposes set out in this section, in accordance with the applicable legal basis.

Without a lawful basis, the company is not permitted to use your personal data. The legal grounds on which the company may process your personal data:

• 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 transfer it to a third-party trading platform.
• The company or a third party may need to process data to pursue their legitimate interests. For example, this may be necessary to improve our services or to defend against legal claims.
• Processing must fulfil a legal obligation.

Please email us for further details about the processing required to safeguard legitimate interests.

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

6. Transfer of Personal Data to Third Parties

The company may also share personal data, including IP address information, with third-party service providers that support us, such as hosting and storage providers, as well as to support the analysis of user experiences.

At your request, we can share specific personal data about you with third-party trading platforms. In such cases, we will pass on the personal data you have provided to us to those third-party platforms. Their use of your personal data is governed by 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. Doing so provides the resources needed to enhance and improve the products and services offered to its customers.

Where necessary to protect third-party rights 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 in our group, in connection with a proposed or actual transaction (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 insolvency of the company or any other business within the group.

7. Cookies and third-party services

Third-party services, including advertising partners on our website and analytics providers, may be used. These organisations may also use cookies and other technologies.

Cookies are small text files stored on your device whenever you visit or use the website. They collect information about your preferences and browsing behaviour to enhance your experience, remember your settings, and tailor the products and services you might enjoy. 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 for a short time, expiring when you close your browser. Other cookies are persistent. These cookies remain on your device for a set period of time after you close your browser. They help the website recognise you as a returning user and make it easier to return to the site.

Types of cookies:

We may use them depending on their purpose:

Cookies are blocked or have been removed

To disable or remove cookies, you’ll need to change your browser settings. The links below will help you through the process 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 operate as you expect if this occurs.

ONLINE TRACKING NOTICE

The Company will retain your personal data for as long as necessary to fulfil the purpose of processing described in this policy, or for longer periods as permitted by applicable laws, regulations, policies, and 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 routinely review the Personal Data we retain to ensure it is no longer required.

9. Transfers of personal data to a third country outside the UK or to an international organisation

Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country—an additional country other than the one in which you reside—or to international organisations or jurisdictions, where applicable). Company takes all necessary steps to protect the personal data you provide and to ensure you can exercise your rights and access effective legal remedies available to you.

These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or an international organisation for which the European Commission has determined that personal data transferred to it is afforded an adequate level of protection, 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 authorities or bodies in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the European Commission’s Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR. 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 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, email info@wealthwaydigital.uk

10. Personal Data Security

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 maintained without error. Nor can we be liable for any intangible, incidental or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosure resulting from transmission errors, unauthorised access by a third party, or any other cause beyond our control.

Where legal or other obligations beyond our control arise, we may be required to disclose your personal data to third parties, including public authorities. In such cases, we cannot control the security measures applied by those third parties to your personal data.

Personal data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any personal data you send to us via the internet.

11. Hyperlinks to third-party websites

This website may include links to third-party websites and applications. These sites and apps are not controlled by the company. We are not responsible for the collection or processing of personal data by them. This Policy does not apply to activities carried out on such sites or apps.

When visiting any third‑party websites or apps, we recommend reading their privacy policies before deciding to access or use them. We also suggest providing 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 promptly notify you by posting the updated policy on our website. For significant updates, we will also endeavour to inform you through methods we consider appropriate and will publish an announcement on our website. Unless stated otherwise, any amendments take effect from the date the revised policy is published.

13. Your rights in relation to your personal data

You are entitled to request that we verify the accuracy of the personal data we hold about you, correct any errors, and delete any personal data we do not require. You may also restrict the scope or types of processing of your personal information.

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

These rights are available to you with respect to the information you provide about your personal data. You may request to exercise the rights you hold by writing an email to the address below.

Access rights

The Company can verify the accuracy of personal data processed about you. If such data are being processed, 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 to you electronically upon request.

The right to access personal data must not infringe the rights and freedoms of others. If a request would adversely affect another person's rights and freedoms, the company may refuse to comply or, where appropriate, limit the extent of its response.

Right to rectification

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

Right to Erasure

The following reasons apply: (a) personal data are no longer required 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 at any time, on grounds relating to your particular situation, where processing of your personal data is 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 the processing is necessary (a) to comply with a legal obligation imposed 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 restrict the processing of your personal data.

If you request that processing of your personal data be restricted, it may thereafter be stored but only processed with your consent, to establish, exercise or defend legal rights, to protect the rights of another natural or legal person, or for reasons of important public interest within the European Union or a Member State.

The 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 rights under the right to erasure. The right to data portability must not prejudice the rights or freedoms of others.

Right to challenge

You have the right to object at any time to any processing of your personal data based on legitimate interests pursued by us or a third party. This also covers profiling carried out solely on the basis of those legitimate interests. We may continue processing your personal data only if we can demonstrate compelling legitimate grounds that override your rights, freedoms or interests, or where processing is necessary for the establishment, exercise or defence of legal rights.

Regarding direct marketing, you have the right to object at any time 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 any processing that relied 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 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 in relation to your personal data, as set out in Section 13.

We will provide the requested information in line 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 needed, depending on the nature of your request and the volume of requests. Within one month of receiving your request, we’ll inform you of any extension and the reasons for it.

Subject to the provisions of section 13 of the law, information you request under your section 13 rights 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 for providing the information or taking the action requested. We may also refuse to act.

If we have any doubts about the identity of the person submitting your request, we may request further information.