Privacy Policy

Your personal data and assets are our highest priority. We are fully committed to keeping them safe.

Foxlume Fund collects and retains data necessary for your trading activities. How this data is collected and stored is set out in the Privacy Policy below.

Our policy is based on the following principles:

• Our aim is to provide complete transparency about how we collect and store your personal data:

Our aim is to ensure you understand how we collect and process all data, so you can make informed decisions. We have clear guidelines and processes for handling data across this website. Our policy sets out the specific methods we use, providing you with clear, concrete information about how it is used. You are in control.

We will always provide information promptly when we determine you should be informed. Transparency is central to our approach.

Our trained team is always on hand to answer any questions you may have about any aspect of our processes, including our obligations under the laws of {country}. You can reach us at info@foxlume-fund.com

• We will not use personal data for any purpose other than as set out in our Privacy Policy.

We may process personal data for the following purposes, including ensuring the proper functioning of {site_name} services and connecting trader-members with third-party trading platforms. We may also process data to maintain and enhance our website and services; protect our rights; and comply with regulatory or other legal obligations. Finally, where necessary, we use this data to provide administrative and other business functions related to the Services we deliver to you, the client.

To provide better services tailored to your preferences and needs, {site_name} uses personal data.

• To enable you to access and use essential tools designed to protect your personal data and safeguard your rights in this respect:

At any time, you can contact us to access all of your personal data. We can also amend or delete it whenever necessary. In addition, we support requests to transfer that data to you or to a nominated third party of your choice. We offer these services to help you fully exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems meet the highest standards, employing banking‑grade measures. While a 100% guarantee is not possible, we remain committed to continually enhancing our systems to the highest attainable level and strengthening the safeguards we have in place.

We maintain a detailed, comprehensive privacy policy and the highest level of security systems.

1. The Scope?

Outlined in this policy are our procedures for the collection, processing, and sharing of any and all data relating to natural persons.

The terms of our policy apply to all natural persons who are identifiable or already identified. This includes any natural person who may be, or has already been, identified through data entrusted to us, and through data we hold or can access, process, link, match, and combine.

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

We do not collect, or attempt to collect, any information about individuals under the age of 18. We also do not permit anyone under the age of 18 to use our platform for any purpose. If we discover a user or any information relating to someone under the age of 18, we will delete that information immediately.

2. What personal data do we hold?

When you register with us, we collect the necessary personal data required to enable you to access and use our services. Where required, we may also ask for additional personal data to verify account ownership, for example. To maintain and improve the highest quality of our services, we collect and analyse information about your use of our platform's services and those of third-party partners.

3. You are under no obligation to provide the company with your personal data at any time.

You are not obliged to share your data, but if you choose not to, we may be unable to provide certain services. It may also limit your ability to use 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 data that can personally identify you. We do, however, gather information such as your account activity, your IP address, and the date and time you access the service. For maintenance, security, and support, we retain system crash reports, browser details, and the type of device used to access your account. We also record your account’s language preference.

Regarding personal data collection, we only collect and retain information you consent to provide when you connect to a third-party trading platform through us.

The personal data you may have provided to third-party platforms can include the following: full name, address, telephone number and email address.

5. Why does the company need my personal data, and is it lawful for them to do so?

Your personal information is collected, stored, and processed by the Company solely for the purposes set out in this Policy. All such uses and processing are carried out in accordance with applicable laws in {country}.

The company will only handle, process, or transfer your data in accordance with the applicable laws in {country}. The following are the legal bases for doing so:

• You have agreed to the company storing and processing your personal data. By submitting your data to the company, you authorise us to transfer it to the relevant third-party trading platform. You have given your consent for your personal data to be processed for one or more purposes.
• To enhance services, establish or defend legal claims, and pursue legitimate interests, among other purposes, the company may need to store and process your personal data.
• Data processing is necessary to comply with legal obligations.

If you would like further information about the data processing the company is required to undertake, please contact us by email.

Below you will find a list of the specific purposes, as well as the legal basis, for which we may process your personal data.

6. Disclosure of Personal Data to Third Parties

To facilitate the storage and processing of IP addresses, the conduct of user surveys and analysis, and other related services, the company may share anonymised personal data with third-party service providers.

At your request, we will share certain personal data you provide with third-party services. In such cases, your data will be handled in accordance with the privacy policies of the relevant company. This may include multiple online trading platforms.

To better serve our clients and enhance our overall services, the company may share personal data with its affiliates and partner organisations.

Where required by law, or to protect the company's rights and assets and those of its third-party partners, we may disclose data to relevant legal or regulatory authorities.

In the event of a significant business transaction—such as the sale of the company, seeking investment, or obtaining a loan—relevant data may be shared in a lawful and appropriate manner. This also applies in the case of any merger, restructuring, consolidation, or insolvency, in accordance with the law.

7. Cookies and Use of Third-Party Services

For site analytics, and in collaboration with advertising partners, cookies and similar technologies may be used, where appropriate, in accordance with applicable law and industry standards.

Cookies—small pieces of code stored on your device when you visit a website—are used to collect information about browsing behaviour, preferences, and more. Their purpose is to personalise and enhance your user experience. They allow us to remember your settings and preferences and to tailor our services accordingly. These cookies are also used for website analytics and to gather statistics for strategic planning.

Broadly speaking, there are two types of cookies used on this site. Session cookies are stored in your browser only for the duration of your visit and are deleted when you close the browser. Persistent cookies remain in your browser even after your session ends. These help the site recognise you as a returning visitor and make it easier to use the site.

Types of cookies:

Cookies may be used where necessary, in accordance with their intended purpose:

Cookies have been blocked or removed

To delete or block cookies, you must do so through your browser’s settings. Follow the links below for step-by-step guidance on how to do this in the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some site functions and features from working as intended.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as needed to carry out the operations described elsewhere in this policy. It may be kept for longer in line with local laws, regulations, and company policies.

Your personal data will be shared - at your request and discretion - with third-party trading platforms for 12 months. When those 12 months expire, and with your consent, that data will be shared for a further 12 months.

Our operations include regular reviews of all personal data to determine whether it remains necessary.

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

When necessary to provide our services and/or for security reasons, personal data may be transferred to third countries (countries outside your own) and to international organisations using robust security protocols. We apply data security measures to the highest possible standard to protect your data and ensure you have access to legal rights and remedies in all cases.

Within the EEA (European Economic Area), all residents are covered by data protection laws and safeguards.

• Data transfers are conducted under the EU’s legal jurisdiction and competence, in line with the data protection standards set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”)
• All data transfers between public bodies or authorities are carried out in accordance with Article 46(2). This constitutes a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, adopted under Article 46(2)(c) of the GDPR, set out the conditions for data transfers and are applied accordingly. The Clauses 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.

For more information on the specific security measures the company uses to protect your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is safeguarded with the highest level of technical and organisational measures, following gold‑standard procedures. These measures help prevent the unauthorised or accidental destruction of data, as well as its loss or alteration.

While we apply the highest levels of care and gold‑standard procedures for data protection, as required by law, it is not possible to guarantee in every circumstance that your personal data will remain error‑free. For that reason, we cannot be held liable where personal data is disclosed, or for loss or damage of an incidental, intangible, or consequential nature. This includes circumstances beyond our control, such as errors in transmission, unauthorised access by third parties, or any other similar cause.

In response to legally binding requests from regulators or legal authorities, we may be required to disclose your personal data to those bodies. Once your data is disclosed under legal obligation, we cannot control how such authorities handle, store, or protect it.

Any information sent over the internet, including personal data, carries a risk of interception and is not 100% secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

This website may include links to third-party applications and websites. Please note that these are not affiliated with us and are outside the company’s control, nor does our privacy policy apply to them. They maintain their own policies and procedures for collecting and processing personal data, and we are not responsible for their practices. Use at your own discretion.

Always read the privacy policy of any company or service when visiting their website, and do so before providing any personal data. Ensure that their data collection, usage, and processing policies align with your preferences and priorities. Any information you choose to share should be provided directly to the service provider.

12. Policy Amendments

We reserve the right to update or amend our policy at any time. We will notify you of any changes via the website and other appropriate channels. The latest version of this privacy policy will be published on the website, and the revised policy will take effect immediately upon publication unless stated otherwise.

13. Your rights in relation to your personal data

You retain full control and the final say over the use of any and all personal data, including the right to verify its accuracy, correct errors, and choose to delete it or restrict both the scope and nature of our data processing.

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

Your personal data is protected by the rights described herein. By sending an email to the address below, you may immediately exercise those rights.

Accessing Your Rights

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

You may request your personal data for verification at any time, and we will provide it to you in electronic format. If you request additional copies of the data we process, beyond the one already supplied, a reasonable fee may apply.

Rights granted by law and our privacy policy must not infringe the rights of others. The company may refuse or restrict access to personal data where such access would compromise the rights and freedoms of others.

Right to Rectification

Any errors in your personal data, whether by omission or incorrect details, may be corrected by you or by the Company to ensure it can be processed correctly.

Erasure Rights

You have the right to request the deletion of your personal data in the following situations. 1) If your personal data has been processed without your consent or in breach of applicable law. 2) When you ask for its removal and the Company has no legal obligation to retain it. 3) If you object to any processing by us, even where it is lawful and based on our legitimate interests or those of a third-party provider, and, finally, 4) If we are required by law to delete your data.

The right to erasure may be overridden by legal obligations under EU law or the laws of any Member State. Likewise, the right does not apply where data is required for the exercise of or defence against legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal data if you believe it contains inaccuracies.

Upon your request to restrict how your personal data is used, it will be deleted except in the following circumstances: 1) where the law of the European Union or a Member State prevents deletion. 2) With your consent, where necessary to establish, exercise, or defend legal claims. 3) To protect the rights of another natural person.

Your right to data portability

You have the right to access and review any personal data you have provided, where you have consented in any manner to its collection and it is processed by automated systems.

You have the right to request that your personal data be transferred to another company or organisation, where this is technically feasible. Exercising this right does not affect your right to have your data erased. This right does not apply where doing so would infringe the rights or freedoms of another individual.

Right to object to data processing

While the Company may rely on its legitimate interests, or those of a third-party service provider, you retain the right to object to processing and request that it cease. This right does not apply where there are compelling legal grounds to continue processing, such as for the establishment, exercise, or defence of legal claims. In such cases, we may continue processing your personal data.

You may at any time request that your personal data not be processed in connection with any direct marketing activities.

Your Right to Withdraw or Refuse Consent

You may withdraw your consent to our processing of your personal data at any time, with immediate effect where possible. This will not affect any processing carried out before you withdrew your consent.

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

If you believe your rights and freedoms have been infringed in connection with the processing of your personal data, EU Member States have established regulatory and supervisory authorities for this purpose. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines circumstances where your personal data rights may be limited under European Union law or Member State legislation.

Once we receive your request about your personal data and its processing, we will provide access to the information you have requested, as set out in Section 13 of this policy. We may extend this timeframe by up to two months, depending on the volume and nature of requests. If an extension is required, we will notify you within one month of receiving your request.

Requested information will be provided to you electronically at no cost, except where doing so would contravene the law or the provisions of Section 13. We reserve the right to charge a reasonable fee, or to decline a request, where it is considered vexatious, excessive, or repetitive.

We reserve the right to request additional proof of identity if there is any reasonable doubt about the individual submitting a personal data request, to uphold data protection and security.