Privacy Policy

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

This Privacy Policy is designed to explain how we collect and store the information you provide via the Highcliff Gainetra website (the “website”).

We will uphold these principles:

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

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

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

We are happy to answer any questions you may have and will provide any clarification you need regarding any limitations imposed by law. You can reach us via email at the address below: info@highcliff-gainetra.com

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

Personal Data may be processed by Us for various purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, complying with legal and regulatory obligations, and carrying out administrative and business activities to enable the provision and use of the Services.

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

• To access essential tools for safeguarding your rights in relation to personal data:

To support you in exercising your rights, we have robust processes in place. Contact us at any time to request access to your personal data. We can amend or delete it, stop using it for specific or all purposes, and transfer it to you or a third party. We will be able to accommodate your requests.

• Protect your personal data:

Although we cannot guarantee the absolute security of your personal data, we commit to continually employing a wide range of robust measures and techniques to ensure that your personal data remains protected.

Our privacy and security policy is finalised.

1. The Scope?

This policy explains the types of personal data the company collects about natural persons and how it is processed, shared with third parties, and safeguarded, among other practices.

This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through other information we hold or can access.

The Policy defines 'processing' as a process that involves the use or collection of personal data. This includes the management, structuring 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 or solicit information from individuals under 18 years of age, and we do not knowingly permit such individuals to use our services. If we become aware that we hold information about children, we will delete it as quickly as we can.

2. What personal data do we hold about you?

When you use our services and channels, or visit our website, we collect personal data. We may request your personal data in certain circumstances. In other cases, we collect it by analysing the use of our services and channels, or by receiving information from our third-party partners.

3. You are under no obligation to disclose personal information to the company or incur consequences.

However, you are not required to provide us with personal data. In certain circumstances, though, if you do not provide specific information, we may be unable to deliver our services or users may be unable 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 information 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, the type of browser you use, and details 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 an online trading platform operated by a third party via Us.

Personal information you provide directly to third-party platforms to facilitate transactions includes your full name, address, telephone number and email address.

5. The lawful basis and the purposes for the processing of personal data

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

Without a lawful basis, the company cannot process 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 transfer it to a third-party trading platform.
• The company or a third party may need to process data to pursue legitimate interests. For example, this may be necessary to improve our services or to defend legal claims.
• Processing must comply with a legal obligation.

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

Below is a list of reasons and legal 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 with third-party service providers that deliver services to us, including hosting and storage, IP address processing, and user experience analysis.

You may also ask us to share specific personal data with third-party trading platforms. In these cases, we will pass on the personal data you have provided to us to the relevant third-party trading platforms. Their use of your personal data is governed by their own 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 Company with 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.

Additionally, we may share your personal data with potential investors or buyers, or with lenders to the company or any other group company, if 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 insolvency of the company or any other business within the group.

7. Cookies and third-party services

We may use third-party services, such as advertising providers for our website or analytics firms. These companies may also use cookies or other technology.

Cookies are small text files stored on your device whenever you visit or use this website. They collect information about your preferences and browsing behaviour to enhance your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistics and analytics.

Some of the cookies we use are session cookies. They are stored temporarily on your device and remain active only until you close your browser. Others are persistent. These stay on your device for a set period after you close your browser. They help the website recognise you as a returning user and enable features that make it easier for you to come back to the site.

Types of cookies:

We may use them depending on their purpose:

Cookies are blocked or deleted

To block 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 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 described 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 to share your data for a further 12 months.

We regularly review the Personal Data we hold to ensure we do not retain it longer than necessary.

9. Transfers of personal data to third countries or international organisations

Your personal information may be transferred to other countries, meaning it may be sent to a third country (i.e. a country other than the one in which you reside), to international organisations, or to other jurisdictions worldwide. 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 clear and effective legal remedies.

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

• Transfer to a third country or an 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 made pursuant to a legally binding, enforceable agreement between public authorities or bodies, by virtue of Article 46(2)(a).
• The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The Clauses adopted by the European Commission are available 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 transferred to third countries or international organisations. Please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect personal data. These include 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 error-free. We are also not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.

In the event of legal obligations or other circumstances beyond our control, we may be required to disclose your personal data to third parties, such as public authorities. In these circumstances, we cannot control how third parties safeguard your personal data.

Personal data cannot be transmitted over the internet with absolute security. The Company cannot guarantee the security of personal data you send to us online.

11. Hyperlinks to websites owned by third parties

Links to third-party websites and applications are provided on this website. These sites and apps are not controlled by the company. We are not responsible for the collection or processing of personal data by these websites or apps. This Policy does not apply to actions taken through 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 advise 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 notify you by posting the revised Policy on our website. For significant updates, we will also seek to inform you through other appropriate methods and will publish a notice on our website. Unless stated otherwise, any amendments take effect upon publication of the revised Policy.

13. Your rights in relation to your personal information

You are entitled to ask that we verify the accuracy of the personal data collected 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 this page:

You are entitled to these rights in relation to the personal data you provide. To exercise them, please contact us by email using the address below.

Access rights

The Company can verify the accuracy of the personal data it processes about you. If your data are being processed, you can access them.

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 provided electronically if you request it.

The right to access personal data must not infringe the rights and freedoms of others. If a request would harm another person’s rights or freedoms, the company may refuse to comply or restrict how it is fulfilled.

Right to rectification

The Company is entitled to rectify inaccurate personal data. You are entitled to request that any incomplete personal data concerning you be rectified, taking into account the purpose of processing.

Right to Erasure

The following reasons apply: (a) the personal data are no longer needed for the purposes 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, to processing based on legitimate interests pursued by us or a third party; (e) the personal data have been processed unlawfully; or (f) the 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 under European Union or Member State law; or (b) to establish, exercise or defend legal rights.

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, we will keep it only with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for important reasons of public interest within the European Union or a Member State.

Right to Data Portability

If the 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 access and review the personal data you have provided to the company.

You have the right to request that your personal data be transferred directly from the company to another controller, if 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 adversely affect the rights or freedoms of others.

Right to challenge

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

Regarding direct marketing, you have the right to object at any time 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 will not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal.

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

You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of personal data within the European Union.

European Union and Member State laws may restrict your rights regarding 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. The timeframe may be extended to up to two months if necessary, depending on the nature of the request and the volume of requests. Within one month of receipt, we will notify you of any extension and the reasons for it.

As long as this does not conflict with the provisions of Section 13 of the law, the information you request under your Section 13 rights will be provided free of charge. If a request is unfounded or excessive, particularly if repetitive, 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 individual who submitted your request, the company may ask you for further information to verify your identity.