Privacy Policy

Your personal data and your assets are our top priority. We are fully committed to protecting them.

Focus Fintrion collects and stores data essential to your trading activities. How we collect and store this data is explained in the following Privacy Policy.

Our policy is guided by the following principles:

• With the goal of ensuring full transparency about our processes for collecting and storing your personal data:

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

We will always provide information promptly if we determine that you need to be informed. Transparency is essential to us.

Our trained staff are always ready to answer any questions you may have about any aspect of our processes, including our obligations under the laws of Canada. You can contact us at: info@focus-fintrion.com

• No other use of personal data is permitted by us except as laid out in our Privacy Policy.

We may process personal data for the following purposes, including the necessary functioning of Focus Fintrion services and connecting trader-members with third-party trading platforms. It may also be necessary for the maintenance and enhancement of website functions and services; protecting our rights, and meeting regulatory or other legal obligations. Finally, insofar as this data is necessary for the provision of administrative and other business functions related to the Services provided to you, the client.

So that we can provide better services that fit your preferences and needs, Focus Fintrion uses personal data.

• In order to be able to use essential tools to protect your personal data and secure your rights in this regard:

At any time you may contact us and access all of your personal data. We can also modify or delete it as needed. We can further support requests to transfer that data to you or to a designated third party. We provide this service and support so that you may better exercise your rights to both privacy and control.

• Protect your personal information:

Our security systems are of the highest quality with banking‑level measures. Nonetheless, a one hundred percent guarantee is not possible, but we are committed to constantly upgrading our systems to the highest possible level and reinforcing the measures we have in place.

We have a detailed and comprehensive privacy policy and the highest level security systems.

1. The Scope?

Outlined in this policy are our procedures for collecting, processing and sharing of any and all data related to natural persons.

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

The processing of data, as defined in the Privacy Policy, specifically refers to the storage, management and organization of that personal data.

We do not collect or seek to collect any information about persons under the age of 18. Nor do we allow persons under the age of 18 to use our platform for any purpose. If we discover any user or any information relating to a person under the age of 18, that information will be deleted immediately.

2. What personal data do we store?

Upon registering with us, we collect necessary personal data to permit you to use our services. When necessary, we may also ask you to provide personal data to prove ownership of an account, for instance. To improve and maintain the highest quality of services, we gather and analyse data related to your use of our platform's services as well as that of third party partners.

3. You are never obligated to provide the company with your personal data.

While you are not under any obligation to provide us with your data, choosing not to provide such information can lead to restrictions on the services we can provide. It may also lead to you being restricted from using our platform.

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

We do not collect data that could be used to personally identify you. We do collect information such as your specific account activity, users' IP address, and the date and time of access. For maintenance, security, and support services, we retain any system crash reports, browser information, and the type of device used to access your account. We also collect information on the language used by your account.

In terms of personal data collection, we only collect and retain the information that you agree to provide us when you connect, through us, with a third party trading platform.

The personal data that you have provided to third party platforms may include the following: full name, address, telephone number, and email address.

5. Why does the company need my personal data and is it legal for them to do so?

The collection, storage, and processing of your personal information by the company are solely for the purposes set out in the Policy. All the above uses and processing are in accordance with relevant laws in Canada.

The company cannot handle, process, or transmit your data except in accordance with the relevant laws in Canada. The following are the legal grounds for doing so:

• You have agreed to allow the company to store and process your personal data. When you submit your data to the company, you grant us permission to transfer that data to the appropriate third-party trading platform. You have provided your consent to the processing of your personal data for one or more purposes.
• In order to improve services, establish or defend legal claims, and pursue legitimate interests, among others, the company may be required to store and process your personal data.
• To meet legal obligations, data processing is required.

If you would like to learn more about the data processing that the company is required to carry out, feel free to contact us by email.

Below you will find a list of the specific uses, as well as the legal basis, for which we may process your personal data.

6. Transfer of Personal Data to Third Parties

For the purposes of storing and processing IP addresses, conducting user surveys and analysis, and other related services, the company may share anonymised personal data with third-party service providers.

Upon your request, we will share specific personal data you provide with third-party services. In this case, the use of your data will be governed by that company’s privacy policies. This may include multiple digital trading platforms.

To enhance services for our clients and improve our services overall, the company may share personal information with its affiliates and partner companies.

As legally required or to protect the company's rights and assets, as well as those of third-party partners, we may disclose data to appropriate authorities of a legal or regulatory nature.

In the case of a critical business transaction such as the sale of the company, pursuit of investment or a loan, the relevant data may be shared in a legal and appropriate manner. This will also include any instance of a company merger, restructuring, consolidation or bankruptcy, as per law.

7. Cookies and Third-Party Services

For the purpose of site analytics, and in partnership with advertising firms, cookies and other technologies of a similar nature may be used in accordance with the law and standard practice.

Cookies - small bits of code that are stored on your device when you visit a website - are used to collect information about browsing behaviour, preferences, etc. Their purpose is to personalize and enhance your user experience. They allow us to remember your settings and preferences, and to tailor service offerings to you on this basis. These cookies are also used for site analytics and to gather 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 the browser is closed. Others are persistent cookies, which remain stored in your browser even after you end a session. These allow the site to recognize you as a returning visitor and make the site easier to use.

Types of cookies:

Cookies may be used as necessary, according to their intended purpose:

Cookies have been blocked or deleted

If you want to delete or block the setting of cookies, you need to do so through your browser's settings. Follow the links below for step-by-step instructions on how to do so with the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some operations and site features from working as intended.

ONLINE TRACKING NOTICE

Your personal data will be stored as long as needed for operations as described elsewhere in this policy. It may be stored longer based upon local laws, regulations and company policies.

Your personal data will be shared, at your request and discretion, with third-party trading platforms for a period of 12 months. Upon the expiration of those 12 months, and with your consent, that data will be shared for a further 12 months.

Our operations include the regular review of all personal data to determine whether it is still needed, or not.

9. Personal data transfers to third countries or international organizations

As needed for providing services and/or for security purposes, personal data is sometimes transferred to third countries (a country other than your own) and to international organizations using full security protocols. We maintain data security protocols at the highest possible level to protect your data and ensure you have access to legal remedies and rights in all cases.

Within the EEA (European Economic Area), all residents are covered by data protection and safeguards.

• Data transfers always occur under the legal jurisdiction and competency of the EU, following standard data protection protocols as set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”)
• Any and all transfers of data between public entities or authorities occur in accordance with Article 46(2). This is a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, under Article 46(2)(c) of the GDPR, establish the conditions for data transfers and are applied accordingly. The Clauses can be found and read 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 on the specific security measures employed by the company to protect your personal data during third country transfers, send a request by email to info@wealthwaydigital.uk

10. Personal Data Protection

Personal data is protected by the highest level of technical and organizational measures, following gold-standard procedures. These procedures are a powerful way to prevent any destruction of data from unlawful or accidental events, as well as loss or alteration of that data.

While we pursue the maximum care and gold standard procedures for data protection, as determined in law, it is impossible to guarantee in all circumstances that your personal data will be maintained error-free. For that reason, we cannot be held liable in cases where personal data is subject to disclosure, or damage of an incidental, intangible or consequential nature. This includes circumstances over which we have no control, such as disclosure resulting from errors in transmission, third-party unauthorized access, or any other cause of this nature.

In the case of legally binding requests from regulators or legal bodies, we may be required to share your personal data with such authorities. Once that data is shared under legal compulsion, we cannot control how those bodies handle, store or protect your data.

Anything sent over the internet, including personal information, carries a certain risk of interception and is not one hundred percent secure. Any data transmitted online cannot be guaranteed secure by the Company.

11. Third-party website hyperlinks

On this website, you will encounter links to third-party applications and websites. Please note that these are not affiliates and are under no control of the company, nor does our privacy policy apply to these companies. They have their own procedures and priorities for the collection and processing of personal data, and we are not responsible for such activities. Use at your own discretion.

Always read the privacy policy of any company or service when you visit their website before providing any personal data. Ensure that their collection, use and processing policies align with your preferences and priorities. Any data you choose to share should be provided directly to the service provider.

12. Policy Amendments

At any time, we reserve the right to update or change our policy. We will provide notice of changes on the website and any other appropriate channels. The updated version of the privacy policy will be posted on the website, and the revised policy will take effect immediately upon publication, unless it is stated otherwise.

13. Your personal data rights

You have full control and the final say over the use of any and all personal data, including verifying its accuracy, correcting errors and/or choosing to delete it or to restrict both the scope and character of any data processing by us.

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

Your personal data and information are protected by the rights described herein. By sending an email to the address below you may immediately exercise those rights.

Accessing Your Rights

If the personal data you have provided to us is accurate, you may access that data at any time. Any of your personal data that is being processed is accessible by us and thus verifiable.

You may request your personal data at any time for verification, and it will be provided to you in electronic format. If you request additional copies of your data that is being processed, in addition to the one provided to you, a reasonable fee may be charged.

The rights provided by law and the privacy policy may not infringe on the rights of others. The company reserves the right to refuse access to personal data or limit access if doing so infringes on the rights and freedoms of others.

Right to Correct Errors

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

Erasure Rights

You have the full right to request deletion of your personal data under the following circumstances. 1) If your personal data has been processed without your consent or outside legal boundaries. 2) If you request that data be removed and the Company has no legal requirement to retain it. 3) If you no longer agree to or accept any data processing by us, even if lawful and within our rights and interests or those of a third party provider, and finally 4) If we are compelled by law to delete your data.

The right to deletion is overridden and superseded by legal obligations imposed by the EU or any member state’s law. Likewise, it does not apply when data is required for the exercise of or defense against legal claims.

Right to Restrict Data Processing

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

Upon request to restrict the use of your personal data, it will be deleted except under the following conditions: 1) where force of law within the European Union or any Member State prevents this. 2) With your consent, if it is required for the purposes of defending against or exercising legal claims. 3) To protect the rights of another natural person.

Right to Data Portability

You have the right to access and review any personal data that you have provided, if you consented, in whatever manner, to its collection and if its processing is carried out by automated systems.

You have the right to request the transfer of any and all personal data to another company or organisation, assuming this is technically possible. This does not affect your right to deletion of your data. It is not permitted where exercising this right would infringe upon the rights or freedoms of another natural person.

Right to contest data processing

Regardless of the Company’s right to pursue our legitimate interests, or those of a third-party service provider, you have the right to object to the processing and demand its cessation. This does not apply where there is a pressing legal need to continue the processing, including to defend against or exercise legal claims. In these cases, we may continue processing your personal data.

You may at any time demand that your personal data not be processed in the service of any direct marketing activities.

Right to Withdraw or Decline Consent

At any time and with immediate effect, where possible, you have the right to withdraw your consent to our processing of your personal data. This is not retroactive to any processing that occurred prior to your withdrawal of consent.

If you are dissatisfied for any reason, you have the right to file a complaint with any legal, regulatory or other supervisory authority.

If you believe that your rights and freedoms have been infringed regarding the processing of your personal data, European Union Member States have established regulatory and supervisory authorities for this purpose. You may submit a complaint to these authorities at your discretion.

Section 13 explains when your personal data rights may be restricted by the laws of the European Union or those of its Member States.

After we receive your request about your personal data and its processing, we will give you access to the information you requested, as described in Section 13 of this policy. We may extend this period by up to two months, depending on the volume of requests and the nature of your request. If an extension is necessary, we will notify you of the extended deadline within one month of receiving your request.

Requested information will be sent to you electronically at no cost, unless this conflicts with the law or the provisions in Section 13. We reserve the right to charge a reasonable fee or refuse a request if it is deemed spurious, excessive or repetitive.

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