Privacy Policy

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

This Privacy Policy is intended to inform you about how we collect and store the information you submit through the Güven Fundex website (the “website”).

These principles will be upheld:

  • To ensure transparency about how we collect and process your personal information:

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

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

We are happy to answer any questions you may have and to provide any clarifications you need regarding any limitations under applicable law. You can reach us by email at: info@guven-fundex.com

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

Personal Data may be processed by Us for various purposes, including providing the website, connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, facilitating the maintenance and delivery of the Services, complying with regulatory or legal obligations, and conducting administrative and business activities that support the provision and use of the Services.

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

  • To access and use essential tools for safeguarding your rights regarding personal data:

To support the exercise of your rights, we provide substantial resources. Contact us at any time to request access to your personal data. We will modify or delete it, and stop using it for specific or general purposes. We can transfer the information to you or to an external party. We will be able to accommodate your requests.

  • Protect your personal data:

While we cannot guarantee the absolute security of your personal data, we are committed to continually applying a range of measures and best practices to help ensure your personal data remains protected.

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 processes and shares this data with third parties, and the safeguards to protect it.

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 other information we hold or can obtain.

The Policy defines “processing” as a process that involves the use or collection of personal data. It covers the management, structuring, and storage of personal data.

Our services are intended for use by general audiences and are not designed for anyone under the age of 18. We do not knowingly collect or solicit information from anyone under 18 years of age, nor do we knowingly allow such individuals to use our services. If we learn that we have collected information about children, we will delete it as promptly as possible.

2. What personal data do we hold about you?

When you access our services or channels, or visit our website, we collect personal data. In some cases, we may ask you to provide this information. In others, we obtain it by analysing how you use our services and channels, or by receiving information about you from our third-party partners.

3. No obligation to disclose personal information to the Company and associated consequences.

However, you are not required to provide us with any personal data. In certain circumstances, though, choosing not to do so may limit our ability to deliver services or prevent users from accessing 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 information about your online activity log, traffic data (such as IP address and the date and time of access), the language you use, software crash logs, 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 when you connect to a third-party online trading platform through us.

Personal information you provide directly to third-party platforms to facilitate transactions includes your full name, address, phone number, and email address.

5. The legal basis and purposes for the processing of 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 valid legal basis, the company cannot use your personal data. The legal grounds under applicable law on which the company is permitted to process your personal data are:

  • You have provided consent to the processing of your personal data for one or more purposes. This may occur 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 legitimate interests. For example, this can be necessary to improve our services or defend legal claims.
  • Processing is required to comply with a legal obligation.

Please contact us by email for more information on the processing required to safeguard legitimate interests.

Below is a list of reasons and legal bases for how 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

If you request it, we may ask for personal data from you to share with third-party companies.

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

To address your requests, questions, or concerns, we require personal data so we can respond to any inquiries you may have regarding the services.

Data must be processed when necessary to pursue the legitimate interests of the company or a third party.

Personal data is processed to fulfill legal, administrative, and judicial obligations and to comply with applicable requirements.

Processing is necessary to comply with legal obligations.

To improve Our Services, we may use Personal Data to support ongoing enhancements. This includes, among other things, crash and malfunction reports that we collect in relation to Our Services.

Processing is necessary 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 aligned with our service requirements, including back-office operations, business development, strategic decision-making, and oversight functions.

Processing is necessary to pursue the company’s legitimate interests or those of a third party.

To conduct analyses that inform decisions on a range of issues, we employ a variety of analytical methods, including statistical techniques.

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

To safeguard our assets, rights, and interests, as well as those of third parties, we may process personal data where necessary to establish, exercise, or defend legal claims. Such processing is conducted to protect our rights, interests, and property, or those of third parties, in compliance with all applicable laws, regulations, and agreements, and with any relevant terms, conditions, or policies.

Processing is necessary for the company's legitimate interests or those of 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 vendors, and may disclose IP address information and user experience analytics.

You may also request that we share specific personal data about you with 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 personal data is 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. This can provide the Company with the resources needed to enhance and improve the products and services it offers to its customers.

When necessary to protect the rights of third parties or assets, the Company may disclose personal data to regulatory, local, or other competent 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, 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

Third-party service providers, such as advertising networks on our website or analytics firms, may be engaged. These providers may also use cookies or other technologies.

Cookies are small text files that are stored on your device each time you visit or access the website. They collect information about your preferences and browsing behavior to enhance your experience, remember your settings, and tailor the products and services you may find useful. Cookies are also used for statistics, performance measurements, and analytics.

Some of the cookies we use are session cookies. These are temporarily stored on your device and remain only for a short time, ending when you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period after you close your browser. They help the website identify you as a returning user and make it easier for you to revisit the website.

Types of cookies:

We may use them according to their intended purpose:

Cookie category

Cookies are strictly necessary

Scope

These cookies are essential for accessing the features you’ve requested and navigating our website. We use them to deliver the information, products, and services you have requested

These are necessary for your device to download and stream data. They enable you to navigate the website, use its features, and return to pages you’ve visited before.

Additional Information

Cookies collect certain personal information, including your username and last login date, to verify your session and confirm you are logged in to the site.

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

Cookie type

Functionality cookies

Scope

Cookies help us recognize you each time you visit our site and remember your preferences and settings.

Additional Information

They remain active 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 data on the site's performance and to improve the site. They also enable us to conduct analysis on our website.

Additional Information

Cookies store anonymous data that is not linked to any identified or identifiable natural person.

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

Cookies are blocked or removed

To block or delete cookies, adjust your browser's settings. Below are links with instructions for several of the most popular browsers.

  • firefox
  • Microsoft Edge
  • Google Chrome
  • safari

However, please note that some or all of the website's 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 fulfill the processing purposes described in this policy, or for longer periods where permitted by applicable laws, regulations, internal policies, or orders.

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

We regularly review the Personal Data we retain to verify that it is no longer needed.

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

Your personal information may be transferred to other countries (i.e., to a third country, meaning a country other than the one in which you reside) or to international organizations and jurisdictions when necessary. The Company takes all necessary measures to protect the personal data you provide and to ensure that data subjects can exercise their rights and obtain access to effective legal remedies, and that appropriate safeguards are applied during any such transfers.

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 pursuant to a legally binding and enforceable agreement between public authorities or bodies, by virtue of 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 approved 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 transferring it to third countries or international organizations. To request this information, email info@wealthwaydigital.uk

10. Personal Data Protection

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 that the security of your personal data will be maintained without error or breach. We cannot 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, personal data disclosed due to transmission errors, unauthorised third-party access, or any other causes beyond our control.

In the event of legal 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 how third parties protect your personal data.

Transmitting personal data over the internet is never completely secure. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to websites owned by third parties

Our website may include links to third-party websites and applications. These sites and apps are not under the Company’s control. We are not responsible for any collection or processing of personal data by those third parties. This Policy does not apply to activities conducted on or through such sites or apps.

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

12. Changes to This Policy

This policy may be updated at any time. If we make changes, we will notify you by posting the updated policy on our website. When we implement significant updates, we will also strive to inform you through the channels we deem appropriate and will publish an announcement on our website. Unless stated otherwise, any amendments will take effect upon publication of the revised policy.

13. Your rights regarding your personal information

You have the right to ask us to verify the accuracy of the personal data being 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 of your personal information.

If you are an EEA resident, please refer to this page:

These rights are available to you regarding the information you provide about your personal data. You may exercise your rights by sending an email to the address below.

Access rights

The Company can verify whether the personal data processed about you is accurate. If so, you may access your personal data.

The Company will provide an electronic copy of your personal data currently being processed and may charge a reasonable fee for 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 person's rights or freedoms, the company may refuse to comply or limit its ability to fulfill the request.

Right to rectification

The Company is authorized 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 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, for reasons related to your particular situation, to processing based on legitimate interests pursued by us or by a third party; (d) Personal data have been processed unlawfully; or (e) 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 can ask the company to limit the processing of your personal data.

If you request restriction of personal data, such data may only be retained with your explicit consent, to establish, exercise, or defend legal claims, to protect the rights and freedoms of another natural person, or where retention is necessary due to a substantial public interest within the European Union or a Member State.

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 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. This right must not interfere with the rights or freedoms of others.

Right to challenge

You may object at any time to the processing of your personal data based on the legitimate interests pursued by the company or a third party. This right also extends to any profiling carried out solely 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 exercise, establishment, or defense of legal rights, we may continue the processing.

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 for us to process personal data about you 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 lodge a complaint with your supervisory authority.

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

European Union and Member State laws may restrict your rights concerning 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 by up to two months if necessary, depending on the nature and volume of requests. We will inform you of any extension and the reasons for it within one month of receiving your request.

Provided this does not conflict with Section 13 of the Law, information you request under your rights in Section 13 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 supplying the information or carrying out the requested action. We may also decline to act.

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