Privacy Policy

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

This Privacy Policy describes how we collect and store the information you provide through the website Kodo Tradeline (the “Website”).

These principles will be upheld:

• To be transparent about how we collect and process your personal information:

We want you to be able to make informed decisions about how your personal data is used and processed. That is why we created this website. To achieve this, we use a range of methods and procedures to provide relevant information about the use of personal data.

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

We are glad to answer your questions and provide any clarifications you need regarding legal limitations. You can reach us by email at the address below: info@kodo-tradeline.com

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

We may process Personal Data for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'); enhancing the site; protecting our rights and interests; maintaining and providing the Services; complying with legal and regulatory obligations; and conducting administrative and business activities to support the delivery and use of the Services.

We also process personal data to gain a better understanding of your preferences and needs.

• To access the essential tools needed to effectively safeguard your rights regarding personal data:

To help you exercise your rights, we have robust processes in place. Contact us anytime to request access to the personal data we hold about you. We can correct or delete it, restrict use for certain purposes, or stop processing altogether upon your request. We can also transfer your information to you or a third party. We will endeavor to fulfill your requests.

• Protect your personal data:

Although we cannot ensure the absolute security of your personal data, we remain firmly committed to continuously employing a wide range of measures, safeguards, and industry best practices to protect it.

Our privacy and security policy is comprehensive.

1. The Scope?

This policy outlines the types of personal data the Company collects about individuals and how it is processed, shared with third parties, safeguarded, and related practices.

This Policy concerns information that is related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified either directly, or indirectly by combining additional information that we hold or that we are able to access.

The Policy defines “processing” as a process that involves the use or collection of personal data. This includes the management, organization, and storage of personal data.

Our services are intended for general audiences and are not designed for individuals under the age of 18. We do not knowingly solicit or collect information from anyone under 18 years of age, and we do not knowingly allow such individuals to access or use our services. If we become aware of any information relating to a child, we will delete it as quickly as we can.

2. What personal data do we hold about you?

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

3. You are not required to provide personal information to the company and the potential consequences.

However, you are not required to provide us with personal data. In some cases, you may choose not to share it. This may limit our ability to provide our services or restrict users' access to the website.

4. What types of personal data can we collect? When you visit our website, we may collect the following personal information:

This includes details about your online activity log, traffic data (such as your IP address and the date and time of access), the language you use, software crash logs, the type of browser used, as well as 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 an online trading platform operated by a third party through Us.

Personal data you submit directly to third-party platforms to enable transactions: this includes your full name, address, phone number, and email address.

5. The legal basis and purposes for processing personal data

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

Without a lawful basis, the Company cannot use your personal data. The legal grounds under which the Company is permitted to process your personal data are:

• You have provided your consent to the processing of your personal data for one or more purposes. For example, when you submit personal information through 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 their legitimate interests. For example, this may be necessary to improve our services or to establish or defend legal claims.
• Processing must comply with a legal obligation.

Contact us by email for more information about the processing we carry out to protect our legitimate interests.

Below is a list of purposes and legal bases for 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 support our operations, including hosting and storage vendors, IP address information services, and user experience analytics providers.

You may also request that we share specific personal data about you with third-party trading platforms. In such cases, we will transmit the personal data you have provided to the relevant third-party platforms. Their use of your personal data will be governed by their respective 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 enables the Company to access the resources needed to enhance and improve the products and services it provides to its customers.

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

We may also share your personal data with potential investors or buyers, or with lenders to the company or any other group company, if a related transaction occurs (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.

7. Third-Party Cookies and Services

Third-party providers, including advertising networks on our site and analytics firms, may be engaged. These providers may also use cookies or other technologies.

Cookies are small text files stored on your device whenever you visit or use this website. We use cookies to collect information about your preferences and browsing behavior to enhance your experience, remember your settings, and tailor products and services that may interest you. Cookies are also used for statistical and analytical purposes.

Some of the cookies we use are session cookies. These are temporarily stored on your device and remain only until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after your browser is closed. They help the website recognize you as a returning user and enable you to come back to the site more easily.

Types of cookies:

We may use them according to their intended purpose:

Cookies are disabled or removed

To disable or delete cookies, adjust your browser's settings. The links below provide guidance for several major browsers

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, please note that some or all of the website's functions and features may not operate as expected if this occurs.

ONLINE TRACKING NOTICE

The Company will retain your personal data for as long as necessary to fulfill the purposes of processing described in this policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.

We regularly review the Personal Data we retain to confirm whether it remains necessary.

9. Transfers of personal information to third countries or international organizations

Your personal information may be transferred to other countries, including to third countries (i.e., countries outside your country of residence) or to international organizations and jurisdictions. The Company takes all necessary measures and implements appropriate safeguards to protect the personal data you provide and to ensure that data subjects can exercise their rights and have access to effective legal remedies in accordance with applicable laws.

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

• Transfer to a third country or international organisation that the European Commission has determined ensures an adequate level of protection for personal data 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 under a legally binding and enforceable agreement between public entities or authorities pursuant to Article 46 (2) (a).
• The transfer was carried out in accordance with the European Commission’s Standard Contractual Clauses adopted under GDPR Article 46(2)(c). 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 on the security measures it uses to protect your personal data when it is transferred to third countries or international organizations. Please email us at info@wealthwaydigital.uk

10. Personal Data Security

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

We cannot guarantee or warrant the error-free security of your personal data. We also cannot be held responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, without limitation, disclosures due to transmission errors, unauthorized third-party access, or other causes beyond our control.

If legal or other obligations beyond our control arise, we may be required to disclose personal data about you to third parties, including public authorities. In these situations, we cannot control the security provided by third parties for your personal data.

No method of transmitting personal data over the Internet is completely secure. The Company cannot guarantee the security of the personal data you send to us online.

11. Hyperlinks to websites operated by third parties

This website may include links to third-party websites and applications. These sites and apps are not operated or controlled by the company. We are not responsible for the collection or processing of personal data by those third parties. This Policy does not apply to activities conducted on such sites or apps.

When visiting any third-party websites or apps, we recommend that you review their privacy policies prior to deciding whether to access or use their apps. We also recommend that you provide any personal data directly to them

12. Amendments to this Policy

This Policy is subject to change at any time. If we update this Policy, we will notify you of those changes by posting the revised Policy on our website. In addition, when we make material modifications to this Policy, we will endeavor to inform you through methods we consider appropriate and will also publish an announcement on our website. Unless expressly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your rights in relation to your personal information

You have the right to ask us to 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 limit the types and scope of processing of your personal data.

If you reside in the EEA, please refer to this page:

These rights are available to you with respect to the information you provide relating to your personal data. You may request to exercise these rights by emailing the address below.

Access rights

The Company is able to verify the accuracy of the personal data being processed about you. If they are accurate, you may access your personal data.

The Company will provide an electronic copy of the personal data it is currently processing and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request.

The right to access personal data must not infringe upon the rights and freedoms of others. If a request would adversely affect another’s rights or freedoms, the company may decline to comply or limit the scope of its response.

Right to rectification

The Company may rectify inaccurate personal data. You have the right to request that any incomplete personal data 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 purposes for which they were collected or processed; (b) You withdraw your consent and there is no other legal basis for processing; (c) You object at any time, on grounds related to your particular situation, to processing 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 deleted 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 its processing.

If you request that processing of personal data be restricted, such data may be retained only with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for reasons of important public interest within the European Union or a Member State.

Data Portability Rights

If 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, where technically feasible. Exercising your right to data portability does not affect 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 have the right to object at any time to the processing of your personal data based on legitimate interests pursued by the company or a third party. This right also applies to profiling carried out solely on the basis of those legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or unless the processing is necessary for the establishment, exercise, or defense of legal rights.

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 file a complaint with your supervisory authority.

You may file 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 regarding your personal data, as described in this 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 period 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.

Provided it does not conflict with Section 13 of the law, information you request under your Section 13 rights will be provided free of charge. If a request is unfounded or excessive—particularly if repeated—we may charge a reasonable fee to cover administrative costs for providing the information or communicating the action taken. We may also decline to act.

If we have any doubts about the identity of the individual who submitted your request—or about whether the requester is the genuine data subject—the company may request further information to verify your identity.