Privacy Policy

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

Hartley Luxeron collects and stores data essential to your trading activity. Our Privacy Policy outlines how we gather and safeguard this information.

Our approach is guided by the following principles:

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

We're committed to helping you understand how we collect and process your data, so you can make informed decisions. We maintain clear guidelines and procedures for handling data across this website, and our policy outlines the specific methods we use. You have complete control over your information.

We're committed to keeping you informed promptly whenever there's something you need to know. Transparency is fundamental to how we operate.

Our knowledgeable team is always available to answer any questions you may have about our processes and regulatory obligations under the laws of United Kingdom. Please contact us at: info@hartley-luxeron.com

• We do not use your personal data for any purpose other than those outlined in our Privacy Policy.

We may process your personal data to support the essential operation of Hartley Luxeron services, connect you with third-party trading platforms, maintain and improve our website functionality, protect our legal rights, and fulfil regulatory obligations. We also process data as necessary to deliver administrative and business functions related to the services we provide to you.

To help us deliver services tailored to your preferences and needs, Hartley Luxeron uses your personal data.

• To safeguard your personal data and protect your rights, you'll need access to essential security tools.

You can contact us at any time to access your personal data, and we can modify or delete it as needed. We also support requests to transfer your data to you or a designated third party. We provide this service to help you exercise your privacy rights and maintain control over your information.

• Safeguard your personal information

Our security systems meet banking-grade standards and are built to the highest specifications. Whilst absolute guarantees cannot be offered, we remain committed to continuously enhancing our defences and strengthening the protective measures we have in place.

We maintain comprehensive privacy policies and employ the highest level of security systems to protect your data.

1. The Scope?

This policy outlines our procedures for collecting, processing and sharing personal data.

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

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

We do not collect or seek information on individuals under the age of 18, nor do we permit anyone under 18 to use our platform. If we discover any user or information relating to a person under 18, it will be deleted immediately.

2. What personal information do we collect and store?

When you register with us, we collect the necessary personal information to enable you to use our services. Where required, we may also ask you to provide personal data to verify account ownership, for example. To continually improve and maintain the highest standard of service, we gather and analyse data relating to your use of our platform and those of our third-party partners.

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

While providing your information is entirely voluntary, choosing not to do so may result in limitations on the services we can offer and could restrict your access to 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 personally identifiable information. However, we do gather data related to your account activity, including your IP address and access timestamps. For maintenance, security, and support purposes, we retain system crash reports, browser details, and information about the device you use to access your account. We also record your account's language preference.

We collect and retain only the personal information you choose to share with us when connecting to a third-party trading platform through our service.

The personal information you have shared with third-party platforms may include your full name, address, telephone number, and email address.

5. Why does the company require my personal data and is it legal to collect it?

The company collects, stores, and processes your personal information solely for the purposes outlined in this Policy. All such uses and processing comply with applicable laws in United Kingdom.

The company can only handle, process, and transmit your data in accordance with applicable data protection laws in United Kingdom. The legal grounds for doing so are as follows:

• By submitting your information to the company, you consent to the storage and processing of your personal data. This includes permission for us to transfer your data to the appropriate third-party trading platform. You acknowledge that you have agreed to the processing of your personal data for the purposes outlined.
• To improve our services, establish or defend legal claims, and pursue legitimate business interests, amongst others, we may need to store and process your personal data.
• To comply with legal requirements, we process your data.

If you'd like to learn more about our data processing practices, please don't hesitate to get in touch with us by email.

Below you will find details of how we may use your personal data, together with the legal basis for each use.

6. Sharing Your Personal Data with Third Parties

To provide anonymised data analytics, conduct user surveys, and deliver related services, Hartley Luxeron may share anonymised personal data with trusted third-party service providers for IP address storage and processing.

At your request, we may share your personal data with third-party service providers, including digital trading platforms. Their use of your information will be governed by their respective privacy policies.

To enhance our service offerings and improve overall service quality, we may share your personal information with our affiliates and partner companies.

We may disclose your data to appropriate legal and regulatory authorities as required by law, or to protect the rights and assets of Hartley Luxeron, our partners, and other third parties.

In the event of a critical business transaction—such as a company sale, investment pursuit, or loan application—we may share relevant data in a legally appropriate manner. This includes situations involving company mergers, restructuring, consolidation, or bankruptcy proceedings, in accordance with applicable law.

7. Cookies and Third-Party Services

We use cookies and similar technologies for site analytics and advertising partnerships, in accordance with applicable law and industry standards.

Cookies are small pieces of code stored on your device when you visit our website. We use them to collect information about your browsing behaviour and preferences, allowing us to personalise your experience and remember your settings. This helps us tailor our services to suit your needs and gather analytics data to improve our platform. By using our official website, you consent to our use of cookies as outlined in our privacy policy.

We use two main types of cookies on our site. Session cookies are temporary and exist only during your browsing session; they're automatically deleted when you close your browser. Persistent cookies, by contrast, remain stored in your browser after your session ends. These enable us to recognise you as a returning visitor and enhance your experience on the site.

Types of cookies:

Cookies may be used as required, in accordance with their intended purpose

Cookies have been deleted or blocked

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

• firefox
• Microsoft Edge
• Google Chrome
• safari

Disabling cookies may prevent certain features and functionality from working as intended on this website.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to fulfil the purposes described in this policy. Retention periods may be extended in accordance with applicable laws, regulations, and our company policies.

Your personal data may be shared with third-party trading platforms at your request and discretion for a period of 12 months. After this 12-month period expires, your data will continue to be shared for a further 12 months, subject to your consent.

We regularly review all personal data we hold to determine whether it remains necessary and appropriate to retain.

9. Personal data transfers to third countries or international organisations

Where necessary for service delivery and security purposes, your personal data may be transferred to third countries and international organisations using rigorous security protocols. We maintain the highest standards of data protection to safeguard your information and ensure you retain full legal rights and remedies in all circumstances.

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

• Data transfers always take place within the legal jurisdiction and regulatory framework of the EU, in accordance with standard data protection protocols established under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
• Any transfer of data between public entities or authorities takes place in accordance with Article 46(2) and constitutes a legally binding and enforceable agreement.
• The European Commission's Standard Contractual Clauses, as established under Article 46(2)(c) of the GDPR, set out the conditions governing data transfers outside the EU. All such transfers comply with these Clauses, which can be reviewed in full at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For further information about the specific security measures used to protect your personal data during transfers to third countries, please contact us at info@wealthwaydigital.uk

10. Personal Data Protection

Your personal data is protected using industry-leading technical and organisational safeguards, implemented according to the highest standards. These measures effectively prevent unauthorised access, accidental destruction, loss, or alteration of your information.

Whilst we implement the highest standards of data protection as required by law, we cannot guarantee that your personal data will remain entirely error-free in all circumstances. Therefore, we cannot be held responsible for any unauthorised disclosure, damage, or loss of your data—whether incidental, indirect, or consequential in nature. This includes situations beyond our control, such as transmission errors, unauthorised access by third parties, or similar unforeseen events.

If we receive legally binding requests from regulatory authorities or legal bodies, we may be required to disclose your personal data to them. Once shared under legal obligation, we cannot control how those authorities handle, store, or protect your information.

Any information transmitted over the internet, including personal data, carries an inherent risk of interception and cannot be guaranteed as completely secure. The Company cannot warrant the security of any data transmitted online.

11. Third-party website links

This website contains links to third-party applications and websites that are not affiliated with us and fall outside our control. Please be aware that our privacy policy does not extend to these external companies, as they operate their own data collection and processing procedures. We are not responsible for their practices. Please use these links at your own discretion.

Always review the privacy policy of any company or service before submitting your personal data on their website. Verify that their data collection, usage, and processing practices align with your preferences and requirements. Any information you decide to share should be provided directly to the service provider.

12. Policy Amendments

We reserve the right to update or modify our policy at any time. Any changes will be communicated to you via the website and other relevant channels. The updated privacy policy will be published on the website and become effective immediately upon posting, unless otherwise specified.

13. Your personal data rights

You maintain complete control over your personal data, including verifying its accuracy, correcting any errors, and choosing whether to delete it or restrict how we process it.

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

Your personal data is protected under the rights described herein. You may exercise these rights at any time by emailing the address below.

Accessing Your Rights

If the personal data you've provided to us is accurate, you can access it at any time. Any of your personal data that we process is accessible to us and therefore verifiable.

You can request your personal data for verification at any time, and we'll provide it to you in electronic format. If you request additional copies beyond the first one, a reasonable fee may be charged.

The rights provided by law and our privacy policy protect the rights of all individuals. Hartley Luxeron reserves the right to refuse or restrict access to personal data where doing so is necessary to safeguard the rights and freedoms of others.

Right to Correct Errors

You may correct any errors or inaccuracies in your personal data yourself, or the Company can do so on your behalf, to ensure your information is processed correctly.

Erasure Rights

You have the right to request deletion of your personal data in the following circumstances: 1) if your data has been processed without your consent or outside legal boundaries; 2) if you request removal and the Company has no legal obligation to retain it; 3) if you withdraw consent to our data processing, even where it is lawful and in our legitimate interests or those of a third party; and 4) if we are legally required to delete your data.

The right to deletion is superseded by legal obligations imposed by EU law or the laws of any member state. Similarly, deletion rights do not apply where data is necessary for the exercise or defence of legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on how your personal information is processed if you believe it contains inaccuracies.

When you request that your personal data usage be restricted, it will be deleted unless one of the following applies: 1) where EU or Member State law prevents deletion; 2) with your consent, if deletion would interfere with your legal defence or the exercise of legal claims; 3) where deletion would harm the rights of another individual.

Your Right to Data Portability

You have the right to access and review any personal data you have provided, provided you consented to its collection and processing by automated systems.

You have the right to request that your personal data be transferred to another company or organisation, provided this is technically feasible. This does not affect your right to request deletion of your data. However, this right cannot be exercised where doing so would infringe upon the rights or freedoms of another individual.

Right to challenge data processing

Regardless of 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 stops. However, this right does not apply where there is a compelling legal reason to continue processing—such as to defend against or pursue legal claims. In such circumstances, we may continue to process your personal data.

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

Right to Withdraw or Decline Consent

At any time, you have the right to withdraw your consent to our processing of your personal data, with immediate effect where possible. Please note that this does not apply retroactively to any processing that occurred before your withdrawal of consent.

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

If you believe your rights and freedoms have been infringed in relation to the processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority in your European Union Member State.

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

When you submit a request regarding your personal data and its processing, we will provide access to the information you've requested, as outlined 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 enquiry. Should an extension be necessary, we will notify you within one month of receiving your request.

We'll send you the requested information electronically at no cost, except where prohibited by law or the terms outlined in Section 13. We reserve the right to charge a reasonable fee or decline requests that are deemed frivolous, excessive, or repetitive.

We reserve the right to request additional proof of identity where we have reasonable grounds to doubt the identity of the person making a request for personal data, in order to ensure data protection and security.