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Privacy Policy

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

This Privacy Policy explains how we collect and store the information you provide through the Blackrose Finbitnex website (the “website”).

These principles will be upheld:

  • To ensure transparency in how we collect and handle your personal information:

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

If we determine that you need specific details, we’ll provide this information at the appropriate date and time.

We are happy to answer any questions and provide any clarifications you need regarding any limitations imposed by law. You can reach us by email at: info@blackrose-finbitnex.com

  • We will only use personal information for the purposes outlined in this policy.

We may process your Personal Data for various purposes, including to provide the website to you, connect you with third-party trading platforms (the 'Services'), improve the site, protect our rights and interests, support the maintenance and delivery of the Services, comply with legal and regulatory obligations, and conduct administrative and business activities that enable the provision and use of the Services.

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

  • Access essential tools to help protect your rights in relation to personal data:

To help you exercise your rights, we offer extensive resources. Contact us any time to request access to the personal information we hold about you. We can update or delete it, and stop using it for specific purposes or generally. We can also transfer the information to you or to a third party. We will accommodate your requests.

  • Protect your personal data:

While we cannot guarantee the absolute security of your personal data, we remain committed to continually applying a range of technical and organisational safeguards, best‑practice measures, and ongoing improvements to help ensure your personal data remains protected.

Our privacy and security policy is finalised.

1. The Scope?

This policy outlines the types of personal information the company collects about individuals, how it is processed, shared with third parties, and safeguarded, along with other relevant practices.

This Policy is about 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 we hold, control, or can access.

The Policy defines 'processing' as any process that involves the use or collection of personal data. It includes the management, organisation, and storage of personal data.

Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from individuals under 18 years old, and we do not knowingly allow such individuals to use our services. If we learn that we hold any information about a child, we will delete it as quickly as we can.

2. What personal information do we hold about you?

When you use our services and channels, or visit our website, we collect personal information. We may ask for your personal information in certain situations. In other cases, we may also obtain your personal information by analysing how our services and channels are used, or by receiving information about you from our trusted third-party partners.

3. There is no obligation to provide personal information to the company and the consequences of not doing so.

While you’re not obliged to provide us with personal information, in some circumstances choosing not to do so may prevent us from delivering certain services or may limit users’ access to the website.

4. What personal information do we collect? When you visit our website, we will collect the following personal information from you:

This includes details about your online activity log, traffic data (including your IP address and the date and time of access), the language you use, software crash logs, your browser type, 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 with 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, phone number and email address.

5. The legal grounds and purposes for processing personal data

Your personal information is processed by the company for the purposes set out in this section and in accordance with the applicable legal basis.

Without a lawful basis under applicable law, the company cannot process personal information about you. The lawful grounds on which the company may process personal information about you include:

  • You have provided 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 we can transfer it to a third-party trading platform.
  • The company or a third party may need to process information to pursue their legitimate interests. For example, this may be necessary to improve our services or to defend against legal claims.
  • Processing must comply with a legal obligation.

Contact us via email for more details about the processing required to protect the legitimate interests.

Below is a list of reasons and legal grounds for how we may use the information you provide us with. Personal data.

Scope
Legal basis

To provide your personal information to third parties at your request to gain access to digital trading

If you ask us to, we may collect your personal information to pass on to third-party companies.

You have consented to the processing of your personal information for one or more purposes.

To respond to your requests, questions, or concerns, we require personal information to address any enquiries you have about our services.

Processing is necessary to pursue the legitimate interests of the company or a third party.

Personal data is processed to comply with legal, administrative, and judicial obligations, and to meet applicable legal requirements.

Processing is required to comply with legal obligations.

To improve our Services, we may use Personal Data. This includes, among other things, any crash or malfunction reports we collect in relation to the Services.

Processing is necessary, in certain cases, to pursue the company’s or a third party’s legitimate interests.

To Prevent Fraud and Misuse of Our Services

Processing is necessary for the company's legitimate interests or those of a third party.

To carry out and manage activities in accordance with our service requirements, including back-office operations, business development, strategic decision-making, governance and oversight functions.

Processing is necessary to pursue the legitimate interests of the company or a third party.

To conduct analyses and support decision-making on various issues, we apply a range of analytical methods, including statistical techniques.

Processing is necessary for the company’s legitimate interests 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 and related matters. We may process personal data, where necessary, to safeguard our rights, interests and assets, or those of third parties, in accordance with all applicable laws, regulations and agreements, and any relevant terms, conditions or policies.

Processing is necessary to pursue the legitimate interests of the company or a third party.

6. Transfer of Personal Data to Third Parties

The company may also share personal data with third-party service providers that support us, including hosting and storage providers, services that process IP address information, and user experience analysis.

You may also request that we share specific personal data about you with third-party trading platforms. In these cases, we will provide the personal data you have given us to those third-party platforms. Their privacy policies will govern how they use your information. Your personal data may be shared with multiple trading platforms.

The Company may share personal information with related entities or business partners. Doing so can provide the Company with the resources needed to enhance and improve the products and services it offers to its customers.

Where reasonably necessary to protect the rights of third parties or assets, The Company is authorised to disclose personal data to regulatory, local, or other competent authorities.

We may also share your personal information with potential investors or buyers, or with lenders to the company or any other entity within our corporate group, if such a transaction occurs (including the transfer or sale of assets belonging to the company or any other group entity) or as part of any merger, restructuring, consolidation, or bankruptcy of the company or any other business within the group.

7. Use of third-party cookies and services

We may engage third-party services, such as advertisers on our website or analytics firms. These companies may also utilise cookies or other technologies

Cookies are small text files stored on your device each time you visit, use, or interact with this website. They collect information about your preferences and browsing behaviour across visits to enhance your experience, remember your settings, and customise the products and services you may find useful and relevant to you. Cookies are also used for statistics and analytics.

Some of the cookies we use are session cookies. These are temporarily stored on your device and last only until you close your browser. Others are persistent cookies. Persistent cookies remain on your device for a set period after you close your browser. They help the website recognise you as a returning user and make it easier for you to return to the website.

Types of cookies:

We may use them according to their purpose:

Cookie type

Cookies are strictly necessary

Scope

These cookies are essential to enable access to the features you’ve requested and to help you 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 allows you to navigate the website, use its features, and return to pages you’ve visited before.

Additional Information

Cookies collect personal information, such as your username and your most recent login date, to confirm that you are logged into the site.

They are deleted when you close your web browser (session cookies).

Type of cookie

Functionality cookies

Scope

Cookies allow us to recognise you each time you visit our website and to also store your settings and preferences.

Additional Information

They persist until their expiry date and remain stored even after the browser is closed.

Cookie type

Cookies for performance

Scope

We use cookies to collect statistical data on our site's performance and to help improve it. They also allow us to conduct analysis on our website.

Additional Information

Cookies store anonymised data that isn't associated with any identified or identifiable natural person.

They can be cleared when you close your browser. Other cookies remain valid indefinitely.

Cookies are blocked or cleared

To block or delete cookies, update your browser settings. The links below provide guidance 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 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 set out in this policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.

We’ll share your information with third-party trading platforms for 12 months. If you consent, we’ll continue sharing your data for a further 12 months.

We routinely review the Personal Data we hold to ensure we don't keep it longer than necessary.

9. Transfers of personal information 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 steps to protect the personal data you provide and to ensure that individuals can assert their rights and access effective legal recourse.

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

  • Transfer to a third country or international organisation that the European Commission has determined ensures 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 carried out under a legally binding and enforceable instrument concluded between public authorities or bodies, pursuant to Article 46(2)(a) of the GDPR.
  • 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. 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-party countries or international organisations. To request this information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect personal data. This includes 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 maintained without error. We also cannot 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, any personal data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

Where we are subject to legal requirements or other obligations outside our control, we may be required to disclose personal information about you to third parties, including public authorities. In such circumstances, we cannot determine or guarantee how those third parties will protect your personal information.

Personal data cannot be transmitted over the internet in an entirely secure manner. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to websites operated by third parties

Our 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 information by those websites or apps. This Policy does not apply to activities carried out through such sites or apps.

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

12. Updates to this Policy

This policy may be updated at any time. If we make changes, we will notify you by posting the revised policy on our website. When significant updates occur, we will also try to inform you using methods we consider appropriate and will publish a notice on our website. Unless stated otherwise, amendments take effect once the revised policy is published.

13. Your rights regarding your personal information

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

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

These rights apply to the personal information you provide about yourself and how it is used. You may exercise these rights at any time by sending an email to the address provided below.

Access rights

The Company can verify whether personal data about you is being processed. If so, you have the right 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. On request, the data will be made available electronically.

An individual’s right to access personal data must not infringe on the rights and freedoms of others. If a request would adversely affect another person’s rights and freedoms, the company may either refuse to process the request or restrict the scope or manner in which it is fulfilled.

Right to rectification

The Company is entitled to correct inaccurate personal information. You are entitled to request that any incomplete personal information about you be corrected, taking into account the purpose of processing.

Right to Erasure

The following reasons 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, on grounds relating to your particular situation, to processing based on our or a third party’s legitimate interests; (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 that requires processing under European Union or Member State law; or (b) to create, exercise or defend legal rights.

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 your personal data be restricted, it may only be retained with your consent; to establish, exercise or defend legal rights; to protect the rights of another natural person; or where retention is necessary for reasons of significant public interest within the European Union or a member state.

Right to Data Portability

If processing is performed by an automated system and relies on your consent or a contract to which you are a party, you have the legal right to access and 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 alter your rights under the right to erasure. The right to data portability must not infringe on the rights or freedoms of others.

Right to challenge

You may object at any time to the use of your personal data based on legitimate interests pursued by the company or a third party. This includes profiling carried out solely on the basis of those legitimate interests. If we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or if processing is required for the exercise, establishment, or defence of legal rights, we may continue processing.

In relation to direct marketing, you have the right at any time to object to the processing of your personal data.

Right to withhold consent

You may withdraw your consent to our processing of your personal data at any time. This won't affect the lawfulness of any processing that relied on your consent before it was withdrawn.

You have the right to lodge a complaint with the authority responsible for supervising you.

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

Laws of the European Union and its Member States may restrict your rights relating to your personal data, as outlined 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 by up to two months if necessary, depending on the nature and number of requests. Within one month of receiving your request, we'll notify you of any extension and the reasons.

As long as doing so does not conflict with section 13 of the law, information requested under your rights set out in section 13 will be provided free of charge. If a request is unfounded or excessive, particularly if it is repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

If we have any doubts about the identity of the individual who lodged your request or the person making the request, the company may request further information.