Privacy Policy

We (also referred to as “We”, “Us” or “Our”) are committed to protecting your personal data and privacy.

This Privacy Policy outlines how we collect and store the information you provide via the Lumi Accord website (the “website”).

We will uphold these principles:

• To provide transparency in the collection and processing of your personal information:

We want you to be empowered to make informed choices about how your personal data is used and processed. That’s why we built our website. We employ various methods and procedures to deliver clear, relevant information on personal data usage.

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

We are happy to answer any questions you may have and will provide detailed clarifications, should you require them, with respect to any limitations imposed by law. You can reach us via email at the address below: info@lumiaccord.net

• We use personal data solely for the purposes outlined in our policy.

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

We also process personal data to gain better insights into your preferences and needs.

• To leverage robust tools that protect your personal data rights:

We have extensive resources to help you exercise your rights. You can contact us at any time to request access to your personal data. We will correct or delete it, restrict its use for specific or general purposes, and transfer it to you or a third party. We are committed to accommodating your requests.

• Safeguard your personal data:

Although we cannot guarantee the absolute security of your personal data, we are committed to using a range of methods and techniques to safeguard it.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy describes the types of personal data the company collects from individuals, and explains how it processes, shares with third parties, and secures that information.

This Policy addresses information concerning an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or recognised through additional information we hold or can 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 a general audience and are not meant for users under the age of 18. We do not knowingly collect personal information from anyone under 18, nor do we knowingly permit minors to access our services. If we discover any data belonging to minors, we will erase it as quickly as possible.

2. What personal data do we hold about you?

When you access our services, channels, or website, we collect personal data. In some cases, we ask you to provide this information directly. In others, we obtain it by analysing your use of our services and channels or by receiving it from our third-party partners.

3. You are not required to provide personal information to the company, and there are no adverse consequences for declining to do so.

You are not required to provide any personal data. However, in some cases, not sharing personal information may prevent us from offering services or restrict website access.

4. What kind of personal data do we collect? When you visit our website, we collect the following personal information:

This includes detailed information about your online activity logs, traffic data (such as your IP address, date and time of access), the language settings you choose, software crash logs, the type of browser you use, and relevant device details including model and operating system. The information collected is not considered private information and cannot be used to identify you.

Personal Data We receive from you: Any personal data you voluntarily provide to Us when you connect with a third-party online trading platform through Us.

Personal information you share with third-party platforms to facilitate transactions: your full name, address, phone number, and email address.

5. The Legal Basis and Rationale for Processing Personal Data

Your personal data is processed by the company for the purposes set out in this section, in accordance with the relevant legal basis.

If no legal basis exists, the company cannot use your personal data. The legal grounds under 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 occurs when you submit personal information on the website, allowing us to 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 could involve improving our services or defending legal claims.
• Processing must comply with a legal obligation.

Contact us via email for further details on the processing required to safeguard the legitimate interests.

Below is a list of the reasons and legal grounds on which we may process the personal data you provide.

6. Transfer of Personal Data to Third Parties

The company may also share personal data, including IP addresses and user experience analyses, with third-party companies that provide services to us, such as hosting and storage providers.

You may request that we share specific personal data about you with third-party trading platforms. In such cases, we will forward the personal data you provided to us to those platforms. Their privacy policies govern the use of your data. Please note that your personal data may be shared with multiple trading platforms.

The Company may share personal data with related entities or business partners. This provides the resources needed to enhance and improve the products and services offered to its customers.

If it is necessary to safeguard the rights or assets of third parties, the Company may disclose personal data to regulatory, local, or other official authorities.

We may share personal data about you with potential investors or buyers, or with lenders to the company or any other company in the group of companies, should the same transaction take place (including the transfer or sale of assets belonging to the company or any other company in the group), or as part of any merger, restructuring, consolidation or bankruptcy of the company or any other business within the group of companies.

7. Third-Party Cookies and Services

Third-party services, such as advertising partners on our website or analytics firms, may be engaged. These providers may also use cookies or other technologies.

Cookies are small text files placed on your device each time you visit or access our website. They gather 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.

Session cookies are temporarily stored on your device and remain active only until you close your browser, enabling short-term functionality during your visit. In contrast, persistent cookies stay on your device for a predetermined period even after the browser is closed. These cookies allow the website to seamlessly recognise you as a returning user, streamline your login process, and provide a more personalised experience on return visits.

Types of cookies:

We may use them according to their intended purpose:

Cookies are blocked or removed

To manage or delete cookies, adjust your browser’s settings. Below are links to guide you through the process for several 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 you expect in this case.

ONLINE TRACKING NOTICE

The Company retains your personal data for as long as necessary to fulfill the processing purposes described in this policy, or for a longer period if required by applicable laws, regulations, policies, or orders.

We’ll share your information with third-party trading platforms for a period of 12 months. If you agree, we’ll extend data sharing for an additional 12 months.

We regularly review the Personal Data we retain to ensure it’s no longer needed.

9. Transfers of Personal Information to Third-Party Countries or International Organizations

Your personal information may be transferred to other countries (for example, to a third country outside your residence) or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide, in compliance with applicable data protection laws, and ensures that you can assert your rights and pursue effective legal remedies.

All residents of the European Economic Area (EEA) have access to these protections and safeguards.

• Transfer to a third-country or international organisation which the EU Commission has determined provides adequate security for personal data transferred to it 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 made pursuant to a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
• This transfer was carried out in accordance with the EU Commission’s standard data protection clauses adopted under Article 46(2)(c) of the GDPR. You can view these 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 on the security measures in place to safeguard your personal data when transferred to third-party countries or international organizations. Send an email to info@wealthwaydigital.uk

10. Security of Your Personal Data

We have implemented comprehensive organizational and technical safeguards to protect personal data. These measures prevent its accidental or unlawful destruction, loss, or alteration.

We cannot guarantee that your personal data will remain completely secure, nor accept liability for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, personal data being disclosed due to transmission errors, unauthorised third-party access, or any other cause beyond our control.

If we face legal or other obligations beyond our control, we may need to disclose your personal data to third parties such as public authorities. We cannot control how third parties secure your personal data in these situations.

Personal data transfers over the web can never be completely secure. The Company cannot guarantee the security of personal data you transmit to us via the Internet.

11. Hyperlinks to third-party websites

Links to third-party websites and applications appear on our website. These websites and applications operate independently and fall outside the company’s supervision. We are not responsible for the collection or processing of personal data by these websites or apps. This Policy does not apply to any actions taken through such sites or apps.

Before deciding to access or use any third-party website or app we recommend, please read its privacy policy. We also suggest that you carefully provide any personal data to them.

12. Updates to this Policy

This Policy may be amended at any time. We will notify you of updates by posting the revised Policy on our website. For significant changes, we will also endeavour to inform you through appropriate channels and post an announcement online. Unless otherwise stated, all amendments take effect upon publication of the updated Policy.

13. Your rights concerning your personal information

You are entitled to request that we verify the accuracy of the personal data collected about you, correct any errors, and delete any personal data we no longer need. You may also limit the types of processing of your personal information.

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

These data protection rights are available to you with respect to all personal data and related information you provide in relation to our services. To exercise these rights, please send your request via email to the address below.

Access rights

The Company can verify the accuracy of any personal data processed about you. If so, you can access that data.

Upon request, the Company will provide an electronic copy of any personal data currently being processed and may charge a reasonable fee for additional copies. The data will be delivered electronically if you request it.

The right to access personal data must not conflict with the rights and freedoms of others. If complying with a request would harm another individual’s rights or freedoms, the company may refuse it or limit the extent of its response.

Right to rectification

The Company may correct any inaccurate personal data. You may request that any incomplete personal data concerning you be rectified, taking into account the purpose of processing.

Right to Erasure

The following reasons are applicable: (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 legal basis to continue processing; (c) you object at any time, for reasons specific to your situation, to the processing of personal data about you that is based on legitimate interests pursued by us or by 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 if 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 rights.

Processing restrictions

If you have concerns about the accuracy of your personal data, you can ask the company to limit its processing.

If you request that your personal data be restricted, we will retain it only with your consent, or when necessary to establish, exercise, or defend legal rights (yours or those of another individual), or where retention serves a significant public interest within the European Union or a member state.

Your Right to Data Portability

If the processing is performed automatically 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 have the right to request that, where technically feasible, your personal data be transferred directly from the company to another controller. Your right to erasure remains unaffected when you exercise your right to data portability. Exercising your right to data portability does not infringe on 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 the legitimate interests pursued by our company or a third party. This right is not limited to profiling activities that rely solely on these interests. If we can demonstrate compelling legitimate grounds for processing your personal data, we may continue to do so unless you can prove that your rights, freedoms or interests, or the establishment, exercise or defense of legal rights, outweigh those grounds.

You have the right at any time to object to processing your personal data for direct marketing purposes.

Right to Withhold Consent

You may withdraw your consent for us to process your personal data at any time. This will not affect the legality of any processing carried out based on your consent prior to its withdrawal.

You have the right to file a complaint with your supervisory authority.

You may lodge an appeal with a supervisory authority appointed by an EU member state to safeguard individuals’ fundamental rights in the processing of personal data within the European Union.

European Union and Member State laws may limit your rights with respect to your personal data, as detailed 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. If needed—depending on the nature and volume of requests—the timeframe may be extended by up to two months. We will notify you of any extension and its reasons within the initial one-month period.

As long as it does not conflict with the provisions of section 13 of the law, any information you request under your rights in that section will be provided free of charge. If a request is unjustified, excessive or repeated, we may impose a reasonable fee to cover administrative expenses for supplying the information or action requested, or we may decline to act.

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