Privacy Policy

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

This Privacy Policy is intended to explain how we collect and store the information you provide through the website Kōdo Tradeline (the “website”).

These principles will be upheld:

• To provide transparency on how your personal information is collected and processed:

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

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

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

• Personal data will be used solely for the purposes described 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'); improving the site; safeguarding our rights and interests; maintaining and delivering the Services; complying with legal and regulatory obligations; and carrying out administrative and business operations that support the provision and use of the Services.

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

• Take advantage of key tools to safeguard your rights with respect to personal data:

To help you exercise your rights, we have substantial resources in place. Contact us at any time to request access to your Personal Data. We can update or delete it and stop using it for specific purposes or entirely. We can also transfer your information to you or to a third party. We will work to accommodate your requests.

• Protect your personal data:

While we cannot guarantee the absolute security of your personal data, we are committed to continuously implementing a comprehensive set of measures, techniques, and best practices to help safeguard it.

Our Privacy and Security Policy is comprehensive.

1. The Scope?

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

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 a combination of additional information we hold or can obtain.

The Policy defines “processing” as any operation that involves 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 designed for individuals under the age of 18. We do not knowingly collect or solicit information from anyone under 18 years of age, nor do we knowingly permit such individuals to use our services. If we become aware that we hold information about a minor, we will delete it as promptly as possible.

2. What personal information do we hold about you?

When you use our services and channels or visit our website, we collect personal data. We may ask you to provide personal data in certain situations. In other cases, we collect personal data by analyzing how you use our services and channels or by receiving information about you from our third-party partners.

3. No obligation to provide personal information to the Company and the consequences of refusal.

However, you are not required to provide us with any personal data. In some cases, though, choosing not to share such data may affect the services we can provide. It may also limit users' ability to access 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 your online activity logs, traffic data (such as IP address and the date and time of access), the language you use, software crash reports, the type of browser, and details about the device you use. The information we collect is not personal data and cannot be used to identify you

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

Personal information you submit directly to third-party platforms for trading purposes includes your full name, address, phone number, and email address.

5. The legal bases and the purposes for processing personal data

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

Without a lawful basis, the company cannot use your personal data. The legal grounds on which the company may process your personal data are:

• You have provided consent to the processing of your personal data for one or more purposes. For example, this applies 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 personal data to pursue legitimate interests. For example, this may be necessary to improve our services or to defend against legal claims.
• Processing must fulfill a legal obligation.

For further details on the processing required to protect legitimate interests, please contact us by email.

Below are the reasons and legal bases under which we may use the information you provide to us, including personal data.

6. Transfer of Personal Data to Third Parties

The company may also share personal data with third-party service providers, such as hosting and storage vendors, who process IP address information and conduct user experience analytics.

You may also request that we disclose specific personal data about you to third-party trading platforms. In such cases, we will share the personal data you have provided to us with those third-party platforms. Their use of your information is governed by their own privacy policies. Your personal data may be shared with multiple trading platforms.

The Company may, from time to time, share personal data with certain affiliated entities and business partners. This can provide the resources necessary to enhance and improve the quality of the products and services it offers its customers.

When 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, buyers, or lenders to the company or any other company in our corporate group in connection with a transaction (including the transfer or sale of assets of the company or any other group company), or as part of any merger, restructuring, consolidation, or bankruptcy of the company or any other business within the group.

7. Cookies and Third-Party Services

We may use third-party services, including companies that provide advertising on our website and analytics firms. These companies may also use cookies or other technologies.

Cookies are small text files stored on your device whenever you visit or interact with our website. They collect information about your preferences and browsing behavior to improve your experience, remember your settings, and tailor products and services you may enjoy. Cookies are also used for statistical and analytical purposes

Some of the cookies we use are session cookies. They are temporarily stored on your device and expire when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the website recognize you as a returning user and make it easier for you to return to the site.

Types of cookies:

We may use them based on their purpose:

Cookies are blocked or have been removed

To block or delete cookies, you'll need to adjust your browser's settings. Below are links to guide you through the process for several of the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, please note that some or all website 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 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 a period of 12 months. If you consent, we will continue to share your data for an additional 12 months.

We regularly review the Personal Data we retain to ensure it is no longer necessary.

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

Your personal information may be transferred to other countries (for example, to a third country—meaning a country other than the one in which you reside—or to international organizations or jurisdictions). The Company takes all necessary steps to safeguard the personal data you provide and to ensure that individuals can assert their rights and obtain 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 carried out pursuant to a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46 (2) (a).
• 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 about the security measures it uses to protect your personal data when transferred to third-party countries or international organizations. To obtain this information, 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 the accidental or unlawful destruction, loss, or alteration of personal data.

We cannot guarantee or warrant the absolute security of your personal data. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures caused by transmission errors, unauthorized access by third parties, or any other circumstances beyond our control.

If we are subject to legal requirements or other obligations 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 the security measures those third parties apply to your personal data.

No method of transmitting personal data over the internet is completely secure. Accordingly, the Company cannot guarantee the security of any personal data you transmit to us through the internet.

11. Hyperlinks to external websites operated by third parties

This website may contain links to third-party sites 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 websites or apps. This Policy does not apply to actions taken on or through such sites or apps.

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

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. When significant updates are made, we will also seek to inform you through appropriate channels and will publish an announcement on our website. Unless stated otherwise, amendments take effect upon publication of the revised policy.

13. Your rights in relation to 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 do not require. You may also limit the scope or types of processing activities for your personal information.

If you are a resident of the EEA, please refer to this page:

You have the following rights regarding the information you provide to us as part of your personal data. To exercise these rights, please send a written request by email to the address below.

Access rights

The Company can verify the accuracy of the personal data processed about you. If so, you may 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. Upon request, the data will be made available electronically.

The right to access personal data must not be exercised in a way that conflicts with the rights and freedoms of others. If a request would harm the rights and freedoms of others, the company may refuse to comply with the request or limit the extent to which it can fulfill it.

Right to rectification

The Company is entitled to correct 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 grounds apply: (a) Personal data are no longer necessary 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, for reasons 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 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 under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.

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

Right to Data Portability

If processing is performed by automated means and is 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 are entitled to request that your personal data be transferred directly from the company to another controller, where 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 interfere with 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 of the company or a third party. This also applies to profiling carried out on the basis of those legitimate interests. If we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or that the processing is necessary for the establishment, exercise, or defense of legal claims, we may continue.

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

Right to Decline Consent

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

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

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

The laws of the European Union and its Member States may limit certain rights you have regarding your personal data, as explained 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 to up to two months if necessary, depending on the nature and volume of requests. We will notify you within one month of receipt if an extension is required and explain the reasons.

As long as doing so does not conflict with Section 13 of the law, the information you request pursuant to your rights under Section 13 will be provided to you 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 associated with 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 submitting your request, the company may request additional information to verify their identity.