Privacy Policy

Your personal information and assets are our highest priority. We are fully committed to safeguarding them.

Bitnote Luxmora collects and retains data necessary for your trading activities. The ways we collect and store this data are outlined in the following Privacy Policy.

Our policy is underpinned by the following principles:

• We are committed to providing full transparency about how we collect and store your personal information:

Our aim is to ensure you understand how we collect and process all data so you can make informed decisions. We have clear guidelines and processes for handling data on this website. Our policy sets out the specific methods we use so you have clear, concrete information about its use. You are in the driver's seat.

We will promptly share information whenever we determine you should be informed. Transparency is central to how we operate.

Our trained staff are always available to answer any questions you may have about any aspect of our processes, including our obligations under Australia law. You can contact us at: info@bitnote-luxmora.com

• We will not use personal data for any purpose other than as set out in our Privacy Policy.

We may process personal data for purposes including the proper operation of Bitnote Luxmora services and connecting trader members with third-party trading platforms. We may also process data to maintain and enhance website features and services, protect our rights, and meet regulatory or other legal obligations. Finally, where personal data is required to provide administrative and other business functions related to the Services we deliver to you, the client.

To deliver better services tailored to your preferences and needs, Bitnote Luxmora uses personal information.

• To be able to access and use essential tools designed to protect your personal information and safeguard your rights in this area:

At any time, you can contact us to access all of your personal information. We can also update or delete it as required. In addition, we can assist with requests to transfer that data to you or to an authorised third party. We offer these services so you can more easily exercise your rights to privacy and control.

• Secure your personal information:

Our security systems are built to the highest standards, using banking-grade safeguards. While a 100% guarantee is not possible, we remain committed to continually upgrading our systems and strengthening the measures we have in place.

We maintain a detailed, comprehensive privacy policy and the highest-level security systems.

1. The Scope?

This policy outlines how we collect, process, and share all data relating to natural persons.

The terms of our policy apply to all natural persons who are identifiable or already identified. This specifically includes any natural person who can be, or has been, identified in relation to data entrusted to us, or data we can access and/or combine.

As defined in the Privacy Policy, data processing specifically refers to the storage, management, and organisation of personal data.

We do not collect, or attempt to collect, any information about individuals under 18. We also prohibit anyone under 18 from using our platform for any purpose. If we become aware of a user account or any information relating to a person under 18, we will delete that information immediately.

2. What personal information do we hold?

When you register with us, we collect the personal data required to enable you to access and use our services. We may also request additional personal data, when needed, to verify account ownership and ensure account security. To maintain and enhance the highest level of service quality, we collect and analyse usage data from our platform as well as from third-party partners.

3. You are under no obligation to provide the company with your personal information.

While you are under no obligation to provide us with your information, choosing not to do so may limit our ability to deliver certain services. It may also restrict your ability to use our platform.

4. What personal information do we collect? When you visit our website, we may collect the following personal information:

We do not collect information that can personally identify you. However, we record details such as your account activity, your IP address, and the dates and times you access the service. For maintenance, security, and support purposes, we retain system crash reports, browser details, and the type of device used to access your account. We also note your account’s language preference.

In relation to personal data collection, we only collect and hold the information you consent to provide when you connect to a third-party trading platform through us.

The personal information you have provided to third-party platforms may include your full name, address, telephone number and email address.

5. Why does the company need my personal data, and is it lawful for them to collect it?

We collect, store and process your personal information solely for the purposes set out in this Policy. All such use and processing complies with applicable laws in Australia.

The company will handle, process, or transmit your data only in accordance with applicable laws in Australia. The legal grounds for doing so are:

• You have agreed to allow the company to store and process your personal information. By submitting your details to the company, you authorise us to transfer them to the appropriate third-party trading platform. You have consented to the processing of your personal information for one or more purposes.
• To improve its services, establish or defend legal claims, pursue legitimate interests, and for other lawful purposes, the company may need to store and process your personal information.
• Data processing is necessary to fulfil legal obligations.

If you would like to learn more about the data processing we are required to undertake, please get in touch with us via email at your convenience.

Below is a list of the specific purposes for which we may process your personal data, along with the legal basis.

6. Disclosure of Personal Data to Third Parties

To facilitate the storage and processing of IP addresses, conduct user surveys and analysis, and provide other related services, the company may, from time to time, share anonymised personal data with third-party service providers.

At your request, we will share certain personal information you provide with third-party services. In such cases, the use of your information will be governed by that company's privacy policy. This may include various digital trading platforms.

To enhance our service to clients and improve overall quality, the company may share personal information with its authorised affiliates and trusted partner organisations.

Where required by law, or to safeguard the company’s rights and assets and those of our third-party partners, we may disclose information to relevant legal or regulatory authorities.

In the event of a significant business transaction, such as the sale of the company, seeking investment, or obtaining a loan, relevant data may be shared in a lawful and appropriate manner. This also applies in the event of any merger, restructure, consolidation, or bankruptcy, in accordance with the law.

7. Cookies and Third-Party Service Providers

For site analytics and in collaboration with advertising partners, we may, from time to time, use cookies and similar technologies on this website, in accordance with applicable laws and standard practice.

Cookies—small data files stored on your device when you visit a website—are used to collect information about browsing behaviour and preferences. Their purpose is to personalise and enhance your experience. They allow us to remember your settings and preferences, and to tailor our services accordingly. We also use cookies for site analytics and to compile statistics for strategic planning.

Broadly speaking, there are two types of cookies used on the site. Session cookies are stored in your browser only for the duration of your session and are deleted when you close the browser. The others are persistent cookies, which remain in your browser after your session ends. These help the site recognise you as a returning visitor and support your use of the site.

Types of cookies:

Cookies may be used as required, in line with their intended purpose:

Cookies are blocked or have been deleted

If you wish to delete or block cookies, you’ll need to do so via your browser settings. Follow the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

If cookies are blocked, some operations and site features will not work as expected.

ONLINE TRACKING NOTICE

Your personal data will be stored for as long as necessary to perform the operations described elsewhere in this policy. It may be retained longer where required by local laws, regulations, or company policies.

Your personal data will be shared, at your request and discretion, with third-party trading platforms for 12 months. When that 12-month period ends, and with your consent, the data will be shared again for a further 12 months.

As part of our operations, we routinely review all personal information to determine whether it is still required.

9. Transfers of personal information to overseas countries or international organisations

As required to deliver our services and for security purposes, personal data may be transferred to third countries (countries outside your own) and international organisations under robust security protocols. We apply the highest standards of data security to protect your data and ensure you have access to legal remedies and rights in all circumstances.

Throughout the EEA (European Economic Area), all residents are protected by data protection laws and safeguards.

• All data transfers are conducted under the EU’s legal jurisdiction and competence, in accordance with the data protection standards set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”)
• All data transfers between public entities or authorities are carried out in accordance with Article 46(2). This constitutes a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, issued under Article 46(2)(c) of the GDPR, set the conditions for data transfers, and such transfers are carried out in accordance with them. The Clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For more information about the specific security measures the company uses to safeguard your personal data during third-country transfers, please email your request to us at info@wealthwaydigital.uk

10. Protection of Personal Data

We protect personal data with best-practice technical and organisational measures, aligned to gold-standard procedures. These measures are designed to prevent unlawful or accidental destruction, loss, or alteration of that data.

While we implement rigorous, best-practice measures for data protection, as required by law, it is not possible to guarantee, in all circumstances, that your personal data will remain entirely error-free and secure. For this reason, we cannot be held liable for any instance in which personal data is disclosed or otherwise impacted, including incidental, intangible, or consequential loss or damage. This includes circumstances beyond our control, such as disclosures caused by transmission errors, third-party unauthorised access, or any other similar cause.

In response to lawful demands from regulators or legal authorities, we may be required to share your personal information with them. Where disclosure is compelled by law, we cannot control how those bodies handle, store or protect your information.

Information sent over the internet, including personal information, carries a risk of interception and is not 100% secure. The Company therefore cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

On this website, you may find links to third-party applications and websites. Please note these are not affiliated with, or controlled by, our company, and our Privacy Policy does not apply to them. They maintain their own policies and procedures for the collection and handling of personal information, and we are not responsible for their practices. You use these links at your own discretion.

Always review a company’s or service’s privacy policy on their website before providing any personal information. Confirm that their data collection, use, and processing practices align with your preferences and priorities. If you choose to share data, do so directly with the service provider.

12. Policy Amendments

We may update or amend this policy at any time. We will notify you of any changes on our website and through other appropriate channels. The updated Privacy Policy will be posted on our website and, unless stated otherwise, will take effect immediately upon publication.

13. Your Personal Data Rights

You retain full control and the final say over how your personal data is used, including verifying its accuracy, correcting errors, and choosing to delete it or restrict both the scope and nature of any processing we perform.

On this page, residents of the EEA can find information relevant to them:

Your personal information is protected under the rights described herein. By emailing the address below, you can immediately exercise those rights.

Accessing Your Rights

If the personal information you have provided to us is accurate, you may access that information at any time. Any of your personal information that we process is accessible to us and therefore verifiable.

You may request your personal data for verification at any time, and it will be supplied to you in electronic form. If you ask for additional copies of the data we are processing, beyond the initial copy, a reasonable fee may apply.

Rights granted under law and in our Privacy Policy must not compromise the rights of others. We may refuse or restrict access to personal information where providing it would infringe the rights and freedoms of others.

Right to Rectify Errors

Any errors in your personal information, whether due to omission or incorrect details, may be corrected by you or by the Company to ensure it can be processed properly.

Erasure Rights

You have the right to request the deletion of your personal data under the following circumstances: 1) if your data has been processed without your consent or outside lawful parameters; 2) upon your request where the Company has no legal requirement to retain that data; 3) if you no longer consent to or accept any processing of your data by us, even if lawful and within our legitimate interests or those of a third-party provider; and 4) where we are required by law to delete your data.

The right to erasure may be overridden by legal obligations imposed by the EU or by any member state’s laws. Likewise, if data is required for the exercise of or defence against legal claims, deletion may not be possible.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal information in circumstances where you believe it contains inaccuracies.

If you request that the use of your personal data be restricted, it will be deleted except in the following circumstances: 1) where European Union or any Member State law prevents this; 2) with your consent, where required to establish, exercise or defend legal claims; 3) to protect another individual’s rights.

Your Data Portability Rights

You have the right to access and review any personal data you have provided, where you have consented in any form to its collection and it is processed by automated systems.

You have the right to request the transfer of any or all personal data to another company or organisation, where technically feasible to do so. This does not affect your right to have your data deleted. This right cannot be exercised if doing so would infringe the rights or freedoms of another individual.

Right to object to data processing

Even though the Company may rely on its legitimate interests, or those of a third‑party service provider, you have the right to object to processing and request that we cease processing. This right does not apply where there is a compelling legal reason or obligation to continue processing, such as to establish, exercise, or defend legal claims. In such circumstances, we may continue processing your personal information as permitted by law.

You may, at any time, object to the processing of your personal data for direct marketing purposes.

Right to Withdraw or Refuse Consent

You may withdraw your consent to our processing of your personal information at any time, with immediate effect where feasible. This will not apply retrospectively to processing that took place before your withdrawal of consent.

If you are dissatisfied for any reason, you are entitled to lodge a complaint with any legal, regulatory or other supervisory authority.

If you believe your rights and freedoms have been breached in relation to the processing of your personal data, European Union Member States have established regulatory and supervisory authorities for this purpose. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines when your personal data rights may be limited under European Union law or the laws of its Member States.

Once we receive your request about your personal data and how it is processed, we will provide access to the information you have requested, as set out in Section 13 of this policy. We may extend this timeframe by up to two months, depending on the volume of requests and the nature or complexity of your request. If an extension is required, we will notify you in writing of any extension and the revised deadline within one month of receiving your request.

The requested information will be provided to you electronically at no cost, unless doing so contravenes the law or the provisions of Section 13. We reserve the right to charge a reasonable fee or refuse a request if it is considered spurious, excessive, or repetitive.

We reserve the right to request additional proof of identity if there is any reasonable doubt about the individual making the personal data request, for the purposes of data protection and security.