Privacy Policy

Protecting your personal data and assets is our highest priority. We are fully committed to safeguarding them.

Ironwood Revolux collects and retains data necessary for your trading activities. How we gather and store this information is set out in the following Privacy Policy.

Our policy is underpinned by the following principles:

• To ensure full transparency about how we collect and store your personal data:

Our aim 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 in place for handling data on this website. Our policy sets out the specific methods we use, giving you clear, concrete information about how your data is used. You are in control of your data.

We will always share information promptly when we determine it's important for you to know. Transparency is fundamental 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 United Kingdom. You can contact us at info@ironwood-revolux.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 Ironwood Revolux services and connecting trader members with third-party trading platforms. It may also be required for the maintenance and enhancement of website features and services, protecting our rights, and complying with regulatory or other legal obligations. Finally, where needed to provide administrative and other business functions related to the Services supplied to you, the client.

To deliver better services tailored to your preferences and needs, Ironwood Revolux processes personal data.

• To ensure you can effectively use essential tools to protect your personal data and uphold your rights in this regard:

At any time, you can contact us to access all your personal data. We can also update or delete it as required. We can likewise facilitate requests to transfer that data to you or to an authorised third party. We provide these services to help you exercise your rights to privacy and control.

• Secure your personal data:

Our security systems are built to the highest standards, with bank‑grade protections. While no system can offer a 100% guarantee, we remain committed to continually enhancing our defences to the highest possible level and strengthening the safeguards we already have in place.

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

1. The Scope?

This policy sets out our procedures for collecting, processing, and sharing any and all personal 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 already been, identified in connection with data that has been entrusted to us, or data we can access and/or combine.

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

We do not collect, or seek to collect, any information about persons under the age of 18. We also do not permit persons under the age of 18 to use our platform for any purpose. Should 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 retain?

When you register with us, we collect the personal data needed to enable your use of our services. Where required, we may also request personal data to verify account ownership, for example. To maintain and improve the quality of our services, we collect and analyse data about your use of our platform and that of our third-party partners.

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

Although you are not required to share your data with us, choosing not to do so may limit the services we can provide to you. It may also restrict your ability to access and use our platform.

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

We do not collect information that could personally identify you. We do, however, collect details such as your account activity, your IP address, and the date and time of access. For maintenance, security, and support services, we retain system crash reports, browser information, and the type of device used to access your account. We also record the language associated with your account.

Regarding personal data collection, we only collect and retain information that you consent to provide to us when you connect, via our service, with a third-party trading platform.

Personal data you have provided to third-party platforms may include: 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?

The company's collection, storage and processing of your personal information is solely for the purposes set out in this Policy. All such use and processing complies with applicable laws in United Kingdom.

The company will only handle, process, or transmit your data in accordance with the applicable laws in United Kingdom. The following are the lawful bases for doing so:

• You consent to the company storing and processing your personal data. By submitting your data to the company, you authorise us to transfer it to the relevant third-party trading platform. You have consented to the processing of your personal data for one or more purposes.
• To improve services, pursue legitimate interests, and establish or defend legal claims, amongst other reasons, the company may need to store and process your personal data.
• To comply with legal obligations, data processing is necessary.

If you would like to learn more about the data processing the company is required to undertake, please contact us by email.

Below is a list of the specific purposes and the legal bases on which we may process your personal data.

6. Disclosure of Personal Data to Third Parties

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

At your request, we will share certain personal data you provide with third-party services. In such cases, the use of your data will be governed by the privacy policies of those companies. This may include multiple digital trading platforms.

To enhance the services we provide to clients and improve overall service quality, the company may share personal data with its affiliates and partner organisations.

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

In the event of a major corporate transaction, such as a company sale, the pursuit of investment or a loan, we may share relevant data in a lawful and appropriate manner. This also applies in the event of any merger, restructuring, consolidation, or bankruptcy, in accordance with the law.

7. Cookies and Third-Party Providers

For site analytics and in collaboration with advertising partners, cookies and similar technologies may be used, in line with legal requirements and industry standards.

Cookies - small text files stored on your device when you visit a website - help collect information about your browsing behaviour and preferences. They are used to personalise and enhance your experience, allowing us to remember your settings and tailor our services accordingly. We also use cookies for site analytics and to gather statistics that support strategic planning.

Broadly speaking, the site uses two types of cookies. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. Persistent cookies remain in your browser even after your session ends. These enable the site to recognise you as a returning visitor and make it easier for you to use the site.

Types of cookies:

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

Cookies are blocked or have been deleted

If you wish to delete or block cookies, you can do this via your browser settings. Follow the links below for step-by-step guidance on how to do so in the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some functions and site features from working properly.

ONLINE TRACKING NOTICE

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

At your request and discretion, your personal data will be shared with third-party trading platforms for 12 months. After that period, and with your consent, it will be shared for a further 12 months.

Our operations include regularly reviewing all personal data to determine whether it is still required.

9. Transfers of personal data to third countries or international organisations

Where necessary to provide our services or for security purposes, personal data may be transferred to third countries (i.e. countries other than your own) and to 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 cases.

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

• All data transfers are carried out 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 the Council of 27 April 2016 (“GDPR”)
• All data transfers between public bodies or authorities are conducted in accordance with Article 46(2). This agreement is legally binding and enforceable.
• The European Commission’s Standard Contractual Clauses, pursuant to Article 46(2)(c) of the GDPR, set the conditions for data transfers, which 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 details about the security measures the company uses to safeguard your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is safeguarded using the highest level of technical and organisational measures, in line with industry best-practice procedures. These procedures are designed to prevent the unlawful or accidental destruction of data, as well as its loss or alteration.

While we apply the highest level of care and gold-standard data protection procedures, as required by law and best practice, we cannot guarantee in all circumstances that your personal data will be kept entirely error-free. Accordingly, we cannot be held liable in any case where personal data is disclosed, or for damage of an incidental, intangible, or consequential nature. This includes, without limitation, situations beyond our control, such as disclosures arising from transmission errors, unauthorised third-party access, or any other similar cause.

In the event of legally binding requests from regulators or other legal authorities, we may be required to disclose your personal data to those bodies. Once disclosed under a legal obligation, we cannot control how those authorities handle, store, or protect your data.

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

11. Links to third-party websites

On this website, you may encounter links to third-party applications and websites. Please note these are not affiliated with us and are outside the company’s control, and our privacy policy does not apply to them. They maintain their own policies and practices for collecting and processing personal data, and we are not responsible for those activities. Use at your own discretion.

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

12. Policy Amendments

We reserve the right to update or amend our policy at any time. We will notify you of any changes via the website and other appropriate channels. The updated privacy policy will be published on the website and will take effect immediately upon publication, unless stated otherwise.

13. Your data protection 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 the scope and nature of our processing.

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

Your personal data is protected under 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 we process is accessible to you and therefore verifiable.

You may request your personal data for verification at any time, and it will be provided to you in electronic format. If you request additional copies of the data we process, beyond the copy already supplied, a reasonable fee may be charged.

Rights granted by law and under this privacy policy must not infringe the rights of others. The company may refuse or restrict access to personal data where disclosure would infringe the rights and freedoms of others.

Right to Rectify Errors

Any errors in your personal data, 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 personal data in the following circumstances. 1) If your data has been processed without your consent or contrary to applicable law. 2) If you ask us to remove it and the Company has no legal obligation to retain it. 3) If you no longer consent to any processing by us, even if lawful and within our legitimate interests or those of a third-party provider. 4) If we are legally required to delete your data.

The right to erasure may be overridden and superseded by legal obligations under EU or member state law. Similarly, data may be retained where it is required for the establishment, exercise, or defence of legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal data 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 cases: 1) where EU or Member State law prevents deletion. 2) With your consent, if needed to establish, exercise or defend legal claims. 3) To protect the rights of another natural person.

Your Data Portability Rights

You have the right to access and review any personal data you have provided if 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 your personal data to another company or organisation, where technically feasible. This does not affect your right to the erasure of your data. This right does not apply where doing so would infringe the rights or freedoms of another individual.

Right to object to processing

Notwithstanding the Company’s right to pursue its legitimate interests, or those of a third-party service provider, you have the right to object to processing and require that it cease. This does not apply where there is a compelling legal need to continue processing, such as to establish, exercise, or defend legal claims. In such circumstances, we may continue processing your personal data.

You may, at any time, request that your personal data not be processed for direct marketing purposes.

Right to Decline or Withdraw Consent

At any time, and where possible with immediate effect, you have the right to withdraw your consent for us to process your personal data. This will not apply retrospectively to any processing undertaken before you withdrew 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 infringed in relation to the processing of your personal data, EU 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 circumstances where your personal data rights may be limited by European Union law or by the laws of Member States.

On receipt of your request concerning your personal data and its processing, we will provide you with 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 of your request. If required, we will notify you in writing of any extension to the deadline within one month of receiving your request.

Requested information will be provided to you electronically, free of charge, unless prohibited by law or the provisions of Section 13. We reserve the right to charge a reasonable fee, or refuse a request, where it is deemed frivolous, excessive, or repetitive.

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