Privacy Notice

We ("We", "Us", or "Our") are dedicated to safeguarding your personal data and privacy

This Privacy Policy aims to explain how we collect and store the information you provide via the Rockley Portdex website (the "website")

These principles will be maintained

• To maintain transparency in how your personal information is collected and processed

We are committed to empowering you to make well-informed decisions regarding the use and processing of personal data. To support this, we have created our website, employing various methods and procedures to offer you relevant information about personal data usage

Should specific details be required, we will furnish you with the information at the designated date and time.

We are happy to answer any questions you have and offer any necessary clarifications on legal restrictions. Please reach out to us via email at the address below: info@rockley-portdex.com

• Personal data will exclusively be used for the purposes outlined in the policy

We may process Personal Data for various purposes, including providing you with the website, connecting you to third-party trading platforms ('the Services'), improving the site, safeguarding our rights and interests, supporting the maintenance and provision of services, complying with regulatory or legal requirements, and executing administrative and business activities to ensure the effective delivery and use of the services

We also handle personal data to gain a deeper understanding of your preferences and needs

• Use vital resources to safeguard your rights regarding personal data

To fully support your rights, we have allocated significant resources. You are welcome to contact us at any time to request access to your personal data. We will amend or delete this data, cease its use for specific or general purposes, or transfer the information to you or a third party. We are dedicated to fulfilling your requests.

• Ensure the security of your personal data:

Although we cannot ensure absolute protection of your personal data, we are committed to employing a range of strategies and methods to safeguard your information

Our privacy and security policy is thorough and robust

1. The Scope?

This policy details the types of personal data the company collects about individuals, as well as the methods used to process, share with third parties, secure, and more

This Policy relates to information concerning an identified or identifiable natural person. An identifiable person is someone who can be directly recognized or determined through a combination of other information we hold or can obtain.

The Policy defines "processing" as any operation involving the use or collection of personal data, including its management, organization, and storage

Our services are designed for a general audience and are not suitable for individuals under the age of 18. We do not intentionally collect or seek information from children under 18, nor do we knowingly allow them to use our services. Should we identify any information pertaining to minors, we will promptly delete it.

2. What personal details do we gather about you?

When you use our services or visit our website, we collect personal data. At times, we may ask for your personal information, while in other cases, we gather it through analysis of your service usage or from our third-party partners

3. The company does not require you to provide personal information and the implications

You are not obligated to share any personal data with us. In certain cases, you may choose not to provide personal data, though this may restrict our ability to deliver services or limit access to the website.

4. What personal data do we collect? During your visit to our website, we may gather the following personal information:

The collected details encompass your online activity log, traffic data (including IP address, date and time of access, and language settings), software crash reports, browser type, and device information. This information is non-private and cannot be used to personally identify you

The personal information you choose to share when accessing a third-party online trading platform via our services

Personal details you provide directly to third-party platforms to enable transactions: these details include your full name, address, phone number, and email address.

5. Legal Basis and Justifications for Processing Personal Data

The company handles your personal data in accordance with the legal guidelines for the purposes described in this section

Without a legal basis, the company is prohibited from using your personal data. Here are the legal grounds the company may rely on to process your personal data:

• By sharing your personal data on this website, you consent to its use for one or more specified purposes, including the potential transfer to a third-party trading platform.
• Processing may be required by the Company or a third party to meet legitimate interests. For instance, improvements to our services or the defence of legal claims might be necessary
• Processing must adhere to a legal obligation

For more details on the processing required to protect legitimate interests, please reach out to us via email

Here are some reasons and legal grounds for which we may utilise the information you provide. Personal data

6. Transfer of Personal Data to External Parties

The company may also share personal data with third-party service providers, such as hosting and storage companies, IP address management, and user experience analysis services

You can also request that we share your specific personal information with third-party trading platforms. In such instances, we will transfer your personal data to these external platforms, and their privacy policies will dictate how your data is used. Your personal information may be shared with multiple trading platforms

The Company may share personal data with affiliated entities or business partners to access essential resources for improving and enhancing its products and services for customers

The Company reserves the right to disclose personal data to regulatory, local, or other official authorities if required to protect third-party rights or assets

In the event of a transaction, such as a transfer or sale of assets, or during a merger, restructuring, consolidation, or insolvency, we may share your personal data with potential investors, buyers, lenders, or any company within our corporate group

7. Cookies and external services

We may utilise third-party services, such as advertisers on our website or analytics firms, which may also employ cookies or other technologies

Cookies are small text files stored on your device whenever you visit or access the website. They gather information about your preferences and browsing habits to improve your user experience, remember your preferences, and customise products and services that may interest you. Cookies are also employed for statistical and analytical purposes

Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only until you close your browser. Other cookies are persistent and remain on your device for a duration after you close your browser. They help the website recognize you as a returning visitor and facilitate your return to the site

Types of cookies:

Their use will be determined by the intended purpose:

Cookies have been blocked or deleted

To manage or delete cookies, please adjust your browser settings. Below are links to guide you through the process for several popular browsers

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some or all website functionalities and features might not perform as intended if this happens

ONLINE TRACKING NOTICE

The Company plans to retain your personal data for as long as necessary to achieve the purposes described in this policy, or longer if permitted by law, regulations, policies, and relevant orders

Your information will be shared with third-party trading platforms for up to 12 months. With your consent, this sharing will continue for an additional 12 months

We routinely review the Personal Data we hold to confirm that it's still necessary.

9. Transferring personal information to a third country or international organization

Your personal information may be transferred to other countries (i.e., to a third country different from your country of residence) or to international organisations. The company implements all necessary measures to safeguard the personal data you provide, ensuring that data users can exercise their rights and access effective legal remedies

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

• Transfer to a third country or international organization deemed by the EU Commission to offer an adequate level of personal data protection, in compliance with Article 45(3) of Regulation 2016/679 of the European Parliament and Council, dated 27 April 2016 (the “GDPR”)
• The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities in compliance with Article 46 (2) (a)
• The transfer was executed in compliance with the EU Commission's standard data protection clauses under Article 46(2)(c) of the GDPR. You can access these EU Commission-adopted Clauses 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 is available to inform you about the security measures in place for safeguarding your personal data when it is transferred to third-party countries or international organisations. To obtain this information, please email info@wealthwaydigital.uk

10. Safeguarding Personal Data

We have established effective organizational and technical measures to safeguard personal data, ensuring protection against accidental or unlawful destruction, loss, or alteration

We cannot guarantee the absolute security of your personal data. Furthermore, we are not liable for any intangible, incidental, or consequential damages resulting from the use or disclosure of personal data. This encompasses, but is not limited to, disclosures due to transmission errors, unauthorized third-party access, or any other causes beyond our control.

If there are legal requirements or other circumstances beyond our control, we may be compelled to disclose your personal data to third parties, such as public authorities. In these cases, we cannot ensure the security measures applied to your personal data by these third parties

Transmitting personal data over the web cannot be completely secure. The Company cannot ensure the security of personal data you send to us via the Internet

11. Links to External Websites

The website provides links to third-party sites and applications. These external sites and apps are not managed by the company. We do not assume responsibility for how personal data is collected or used by these third parties. This Policy does not apply to activities conducted via those sites or apps

When visiting any third-party websites or apps, we suggest reviewing their privacy policies before deciding to use their services. We also recommend carefully considering sharing your personal data with them

12. Changes to this Policy

This policy is subject to change at any time. Should we make any modifications, we will update the policy on our website to keep you informed. For significant changes, we will make every effort to notify you via suitable methods and will post a notice on our website. Unless otherwise mentioned, changes will take effect once the revised policy is posted.

13. Your rights regarding your personal information

You are entitled to request verification of the accuracy of your collected personal data, correct any inaccuracies, and delete any unnecessary personal data. Additionally, you can restrict certain types of personal information processing.

If you are an EEA resident, kindly visit this page:

In relation to the personal data you provide, you are entitled to certain rights. To exercise these rights, please send a request via email to the address provided below

إذن الوصول

The Company can confirm the accuracy of the personal data being processed about you; if it is, you will be granted access to your personal data

The Company is pleased to offer an electronic copy of your personal data currently being processed and may charge a reasonable fee for any extra copies. If requested, the data will be supplied electronically.

The right to access personal data must be balanced with the rights and freedoms of others. If a request infringes upon these rights and freedoms, or those of an individual, the company may refuse or limit its ability to fully comply with the request.

Right to correction

The Company reserves the right to rectify inaccurate personal data. You are entitled to request the correction of any incomplete personal data related to you, taking into account the purpose of processing

Right to Erasure

The following conditions justify the actions: (a) Personal data are no longer necessary for the purpose they were originally collected or processed; (b) You withdraw consent, and no other legal basis exists for processing; (c) You object, based on your particular situation, to the processing of personal data concerning you that relies on our or a third party's legitimate interests; (e) The personal data are processed unlawfully; or (f) Personal data must be erased to comply with the company's legal obligations

This right does not apply if the processing is required (a) to comply with an obligation mandated by European Union law or the law of a member state; or (b) to establish, exercise, or defend legal claims

Processing restrictions

If you have concerns about the accuracy of your personal information, you may request that the company restrict the processing of your data

Should you request the restriction of personal data, such data may only be retained with your consent, to establish, exercise, or defend legal claims, to safeguard another individual's rights, or due to a compelling public interest within {country} or a member state

Entitlement to Data Portability

If an automated system processes your data based on your consent or a contract you are a part of, you are legally entitled to review the personal data you have provided to the company

You are entitled to request the direct transfer of your personal data from the company to another controller, provided it is technically feasible. Exercising the right to data portability does not impact your rights under the right to erasure. The right to data transfer must not infringe upon the rights or freedoms of others.

Right to challenge

You have the right to object to any processing of your personal data based on the company's or a third party's legitimate interests at any time. This includes profiling solely based on these legitimate interests. We may continue processing your personal data if we can demonstrate compelling legitimate grounds that outweigh your rights, freedoms, or interests, or for the establishment, exercise, or defense of legal rights.

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

Right to Decline Consent

You may withdraw your consent for us to process your personal data at any time. This will not affect the lawfulness and validity of any processing carried out with your consent prior to the withdrawal.

You are entitled to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with a supervisory authority established by an EU member state, dedicated to safeguarding individuals' fundamental rights concerning the processing of personal data within the European Union

Legislation within the EU and its Member States may restrict your rights concerning personal data, as detailed in section 13

We will supply the requested information in line with your rights as outlined in section 13 of this agreement within one month of receiving your request. If required, the response time may be extended by up to two months, depending on the complexity and number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons behind it.

Provided it does not conflict with the stipulations of section 13 of the law, the information you request under your rights in section 13 will be supplied at no cost. However, if the request is unfounded or excessive, especially if repeated, we may impose a reasonable fee to cover the administrative expenses involved in supplying the information or undertaking the requested action. We may also choose not to proceed

If there is any uncertainty regarding the identity of the individual who submitted your request, the company may ask for further information.