Privacy Policy

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

This Privacy Policy sets out how we collect and store the information you provide through the website Stonegate Bitflow (the “website”).

We will defend these principles:

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

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

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 clarifications you require regarding any legal limitations that may apply. You can contact us by email at the address below: info@stonegate-bitflow.com

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

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

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

  • To use essential tools to protect your rights in relation to personal data:

To support the exercise of your rights, we have comprehensive processes in place. Contact us at any time to request access to your personal data. We can correct or delete it, and restrict or stop its use for specific purposes or more generally. We can also transfer your information to you or to a third party. We will endeavour to fulfil your requests.

  • Protect your personal data:

Although we cannot guarantee the absolute security of your personal data, we are committed to continually using a range of measures and techniques to ensure your personal data remains protected.

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, secured, and otherwise handled.

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

The Policy defines 'processing' as a process that requires 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 anyone under 18. We do not knowingly collect information from individuals under the age of 18, nor do we knowingly permit such individuals to use our services. If we become aware of any information about children, we will delete it as quickly as possible.

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 instances. In other instances, we collect personal data by analysing how our services and channels are used or by receiving your information from our third-party partners.

3. There is no requirement to disclose personal information to the company and the associated consequences.

You are not obliged to provide us with personal data. However, in certain circumstances, if it is not supplied, we may be unable to provide some services in full, and 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 your online activity log, traffic data (such as your IP address and the date and time of access), your preferred language, software crash logs, your browser type, and details about the device you use. The information we collect is not personal 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 a third-party online trading platform through Us.

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

5. Lawful basis and reasons for processing personal data

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

Without a lawful basis, the company cannot use personal data relating to you. The legal grounds on which the company is permitted to process your personal data are as follows:

  • You have consented to the processing of your personal data for one or more purposes. This includes instances where you submit personal information via the website so that we can transfer it to a third-party trading platform.
  • The company or third parties may need to process data to pursue their legitimate interests. For example, this may be necessary to improve our services or to establish, exercise, or defend legal claims.
  • Processing must fulfil a legal obligation.

Contact us by email for more details about the processing required to protect our legitimate interests.

Below is a list of reasons and lawful bases on which we may use the information you provide to us. Personal data.

Scope
Legal basis

To share your personal data with third parties, at your request, to enable access to digital trading

At your request, we may ask for your personal data to share with third-party companies.

You have given your consent to the processing of your personal data for one or more purposes.

To respond to your requests, questions, or concerns, we require personal data to address any queries you may have about our services.

Processing is necessary for the purposes of the legitimate interests pursued by the company or by a third party.

To comply with any legal, administrative or judicial obligations, personal data is processed to meet legal requirements.

To comply with legal obligations, processing is necessary.

To improve Our Services, we may use Personal Data for this purpose. This includes, among other things, any crash or malfunction reports that we collect in relation to Our Services.

It is necessary to process data for the company's legitimate interests or those of a third party.

To Prevent Fraud and Misuse of Our Services

Processing is necessary for the legitimate interests of the company or a third party.

To carry out and manage activities that align with our service requirements, including back-office operations, business development, strategic decision-making, governance, oversight and related functions.

Processing is necessary for the legitimate interests of the company or of a third party.

To undertake analysis, including statistical analysis to inform decisions on a range of issues, we use a variety of analytical techniques (including statistical methods).

Processing is necessary for the purposes of the legitimate interests pursued by the company or a third party.

To protect our assets, rights, and interests, as well as those of third parties, we have put in place measures to establish, assert, and defend legal claims. Personal data may be processed by us, where necessary, to safeguard our rights, interests, and assets, or those of third parties, in compliance with all applicable laws, regulations, and agreements, and any relevant terms, conditions, or policies.

Processing is necessary for the legitimate interests of the company or a third party.

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 partners, to process relevant IP address information and to analyse aggregated user experiences.

You may also ask us to 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. The use of your personal data will then be governed by their privacy policies. Your personal data may be shared with multiple trading platforms.

The Company may share personal data with affiliated entities or business partners. Doing so can provide the resources needed to enhance and improve the products and services offered to its customers.

Where necessary to protect the rights of third parties or property, The Company may disclose personal data to regulatory, local or other official authorities.

We may also share your personal data with potential investors or buyers, or with lenders to the company or any other company in our group of companies if such a transaction takes place (including any 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 engage third-party services, such as advertisers on our website or analytics providers. These third parties may also use cookies or other technologies

Cookies are small text files that are stored on your device every time you visit or access this website. They collect information about your preferences and browsing behaviour to enhance your experience, remember your settings, and customise the products and services you are most likely to enjoy. Cookies are also used for statistics and analytics.

Some of the cookies we use are session cookies. These are temporarily stored on your device and last for a short time until 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 recognise you as a returning user and enable you to return to the website.

Types of cookies:

We may use them depending on their purpose:

Cookie type

Cookies are strictly necessary

Scope

These cookies are essential to enable the features you have requested and to help you navigate our website. We use cookies to deliver the information, products and services you have requested from us.

They are essential for your device to download and stream data. This enables you to navigate the website, utilise its features, and return to pages you’ve visited before.

Additional Information

Cookies store personal data, including your username and last login date, to confirm that you are logged in to the site.

They are deleted when you close your web browser (session cookies).

Cookie type

Functionality cookies

Scope

Cookies help us recognise you each time you visit our site and also save your site settings and preferences.

Additional Information

They remain valid until their expiry date and are retained even after the browser is closed.

Type of cookie

Cookies for performance

Scope

We use cookies to collect statistical information about the site's performance and to help improve it. They also enable us to analyse how our website is used.

Additional Information

Cookies store anonymous data that is not associated with any identifiable or identified natural person.

They can be deleted when you close your browser. Other cookies remain valid indefinitely.

Cookies are blocked or cleared

To block or delete cookies, adjust your browser settings. The links below explain how to do this in a number of popular browsers.

  • firefox
  • Microsoft Edge
  • Google Chrome
  • safari

However, please note that some or all website functions and features 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 processing purposes set out in this policy, or for longer where permitted by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for 12 months. With your consent, we will continue sharing your data for a further 12 months.

We regularly review the Personal Data we hold and delete any that is no longer needed.

9. Transfers of personal data to a third country or an international organisation

Your personal information may be transferred to other countries, including to a third country (a country other than the one in which you reside) or to international organisations and other jurisdictions. Company takes all necessary measures to protect the personal data you provide and to ensure that individuals can assert their rights and access effective legal remedies.

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 provides 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 under a legally binding and enforceable agreement between public bodies 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 Article 46(2)(c) of the GDPR. You can view these Clauses on the Commission’s website 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 safeguards it uses to protect your personal data when transferred to third countries or international organisations. To request this information, email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organisational and technical measures to safeguard personal data. These measures prevent 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 maintained without error. Nor can we be held liable for any intangible, incidental or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, any disclosure caused by transmission errors, unauthorised third-party access, or other circumstances beyond our control.

If we are subject to legal requirements or other obligations beyond our control, we may be required to share your personal data with third parties, such as public authorities. In these circumstances, we cannot control the safeguards applied to your personal data by those third parties.

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

11. Hyperlinks to third-party websites

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 activities conducted through such sites or apps.

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

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. In addition, when we implement significant updates, we will seek to inform you through channels we consider appropriate and will also publish an announcement on our website. Unless stated otherwise, any amendments will take effect once the revised policy has been published.

13. Your rights concerning your personal data

You are entitled to ask us to verify the accuracy of the personal data we hold about you, to correct any errors, and to 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 a resident of the EEA, please refer to this page:

These rights are available to you in respect of the information you provide concerning your personal data. If you wish to exercise your rights, please do so by sending an email to the address below.

Access rights

The Company can verify the accuracy of the personal data being processed about you. If they are, you will be able to 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. If you request it, the data will be supplied electronically.

The right to access personal data must not infringe the rights and freedoms of others. If a request would be detrimental to another person’s rights or freedoms, the company may refuse to comply with the request or limit its ability to fulfil it.

Right to rectification

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

Right to Erasure

The following grounds 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, on grounds relating to your particular situation, to processing based on our or a third party’s legitimate interests; (e) the personal data have been processed unlawfully; or (f) the personal data must be erased to comply with the company’s legal obligation.

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 restrict the processing of your personal data.

If you request that your personal data be restricted, it may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or where there is a significant public interest within the European Union or a Member State.

Your right to data portability

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 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 it is technically feasible and secure to do so. Exercising your right to data portability does not limit or alter your right to erasure or any other data protection rights. This right must not adversely affect the rights or freedoms of other individuals in any way.

Right to challenge

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

In relation to 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 won't affect the lawfulness of any processing that relied on your consent prior to its withdrawal.

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

You may lodge 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 limit 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 by up to two months if necessary, depending on the complexity of your request and the volume of requests we receive. We will inform you within one month of receipt if an extension is required and explain the reasons.

Provided this does not conflict with the provisions of section 13 of the law, information you request under your rights in section 13 will be supplied 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 taking the requested action. We may also choose not to act.

If we have any doubts about the identity of the person who submitted your request, the company may request further information to verify your identity.