Privacy Policy

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

Barclay Valnor collects and retains data necessary for your trading activities. How we collect and store this data is set out in the Privacy Policy below.

Our policy is underpinned by the following principles:

• To provide complete transparency about how we collect and store your personal data:

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

We will always share relevant information promptly whenever we determine you should be informed. Transparency is central to us.

Our trained staff are on hand to answer any questions you may have about our processes, including our obligations under United Kingdom law. You can contact us at: info@barclay-valnor.org

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

We may process personal data for the following purposes, including ensuring the proper functioning of Barclay Valnor services and connecting trader members with third-party trading platforms. We may also do so to maintain and enhance website features and services, protect our rights, and meet regulatory or other legal obligations. Finally, where this data is needed to deliver administrative and other business functions related to the Services provided to you, the client.

In order to provide better services that meet your preferences and needs, Barclay Valnor uses personal data.

• To access the essential tools you need to protect your personal data and exercise your rights in this area:

You can contact us at any time to access all of your personal data. We can also update or delete it as required. We can support requests to transfer that data to you or to a nominated third party. We provide these services so you can better exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems are built to the highest standards, employing bank-level controls. While a 100% guarantee is not possible, we are committed to continually upgrading our systems and strengthening the protections we have in place.

We maintain a detailed, comprehensive privacy policy and state-of-the-art security systems.

1. The Scope?

This policy outlines our procedures for collecting, processing, and sharing all data relating to any natural person.

Our policy applies to all natural persons who are identifiable or already identified. This specifically includes any individual who can be identified, or has been identified, in connection with data entrusted to us or information 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 seek to collect, any information about individuals under the age of 18. We also do not allow individuals under the age of 18 to use our platform for any reason. If we discover any user account or any information relating to a person under the age of 18, that information will be immediately deleted.

2. What personal data do we hold?

When you register with us, we collect the personal data necessary to enable you to use our services. When necessary, we may also ask you to provide personal data to verify ownership of an account, 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 at any time to share your personal data with the company.

Although you are not obliged to share your data, choosing not to may limit the services we can provide. It may also result in your access to our platform being restricted.

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 be used to personally identify you. We do collect details including your account activity, IP addresses, and the dates and times of access. For maintenance, security, and support purposes, we retain system crash reports, browser information, and the type of device used to access your account. We also record the language preference associated with your account.

Regarding personal data, we only collect and retain the information you consent to share with us when you connect, through us, with a third-party trading platform.

The personal data you have supplied 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?

The Company collects, stores, and processes your personal information solely for the purposes set out in this Policy. All such uses and processing comply with the relevant laws in United Kingdom.

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

• You have agreed to allow the company to store and process your personal data. By submitting your information 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 specified purposes.
• To improve services, pursue legitimate interests, and establish or defend legal claims, among other purposes, the company may need to store and process your personal data.
• Data processing is required to comply with legal obligations.

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

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

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

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

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

Where required by law, or to protect 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 corporate transaction, such as the sale of the company, securing investment, or arranging a loan, relevant data may be shared in a lawful and appropriate manner. This also applies in the case of any merger, restructuring, consolidation, or insolvency, in accordance with the law.

7. Use of Cookies and Third-Party Services

For site analytics and in collaboration with advertising partners, cookies and similar technologies may be used in accordance with applicable law and industry standards.

Cookies — small text files stored on your device when you visit a website — are used to collect information about browsing behaviour, preferences and similar details. 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 website analytics and to compile statistics that support strategic planning.

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

Types of cookies:

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

Cookies are blocked or deleted

To delete or block cookies, please use your browser's settings. Follow the links below for step-by-step guidance for the most widely used browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

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

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as is necessary to perform the operations described elsewhere in this policy. It may be retained longer in accordance with local laws, regulations and company policies.

Your personal data will be shared—at your request and at your discretion—with third-party trading platforms for 12 months. Once the initial 12-month period ends, 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 remains necessary.

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

When necessary to deliver our services or for security reasons, personal data may be transferred to third countries (countries outside your own) and to international organisations under robust security safeguards. We apply the highest standards of data protection to safeguard your information and to ensure your rights and legal remedies remain available in all circumstances.

Throughout the EEA (European Economic Area), all residents benefit from 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 of the Council of 27 April 2016 (“GDPR”)
• All data transfers between public bodies or authorities take place in accordance with Article 46(2). This arrangement is legally binding and enforceable.
• The European Commission’s Standard Contractual Clauses, adopted under Article 46(2)(c) of the GDPR, define 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 on the specific 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 best-practice standards. These measures are a robust way to prevent unauthorised or accidental data destruction, as well as the loss or alteration of that data.

While we exercise the highest levels of care and follow industry-leading data protection practices as required by law, it is not possible to guarantee in every circumstance that your personal data will remain error-free. Accordingly, we cannot be held liable in any case where personal data is disclosed, or for loss or damage of an incidental, intangible, or consequential nature. This extends to events beyond our control, including disclosure arising from transmission errors, unauthorised access by third parties, service interruptions or technical failures, or any other similar cause.

If required by law or by binding requests from regulators or legal authorities, we may be obliged to disclose your personal data to them. Once shared under such legal obligation, we cannot control how those authorities handle, store, or protect your data.

Everything sent over the internet, including personal data, carries a risk of interception and is not completely secure. The Company cannot guarantee the security of any data you transmit online.

11. Links to third-party websites

On this website you may encounter links to third-party applications and websites. Please note that 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 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 organisation or service on its website before sharing personal data. Ensure its 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

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 all personal data is used, including verifying its accuracy, correcting errors, and deciding whether to delete it or to restrict both the scope and nature of any processing we carry out.

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

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

Accessing Your Rights

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

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

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

Right to Rectification

Any inaccuracies in your personal data, whether through 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 in the following situations: 1) if your data has been processed without your consent or outside lawful limits; 2) if you ask us to remove it and we have no legal obligation to retain it; 3) if you no longer agree to our processing, even where lawful and based on our or a third-party provider’s legitimate interests; and 4) if we are required by law to delete your data.

The right to erasure may be overridden by legal obligations under EU or member state law. Likewise, this right does not apply where data 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 if you believe it is inaccurate.

Upon your request to restrict the use of your personal data, it will be deleted except in the following circumstances: 1) where the law of the European Union or any Member State prevents deletion; 2) with your consent, if it is required to establish, exercise or defend legal claims; 3) to protect the rights of another natural person.

Your Right to Data Portability

You have the right to access and review any personal data you have provided, if you have consented in any manner 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 have your data deleted. This right cannot be exercised where doing so would infringe the rights or freedoms of another individual.

Right to object to data processing

While the Company may rely on our legitimate interests, or those of a third-party service provider, you have the right to object to processing and request that it cease. This does not apply where there is a compelling legal reason to continue, including the establishment, exercise, or defence of legal claims. In such circumstances, we may continue to process your personal data.

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

Your Right to Withdraw or Decline Consent

You may withdraw your consent to our processing of your personal data at any time and, where possible, with immediate effect. This does not apply retroactively to any processing carried out before your withdrawal of consent.

If you are dissatisfied for any reason, you have the right 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, each European Union Member State has established regulatory and supervisory authorities to address such matters. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines circumstances in which your personal data rights may be limited by 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 give you access to the information you have asked for, 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 an extension is required, we will notify you of the new deadline within one month of receiving your request.

We will provide the requested information electronically at no charge, unless doing so would contravene 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 where there is reasonable doubt about the individual making a request for personal data, to meet our data protection and security obligations.