Privacy Policy
Last update: 29.03.2026
We (also referred to as "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 provide through the website Spire Fundvex (the "Website").
These principles will be upheld:
To be transparent about how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we have created our website. To support this, we use different methods and procedures to provide you with relevant information about the use of Personal Data.
If we believe you need specific details, we will provide that information at the appropriate time.
We are happy to answer any questions you may have and provide any clarification you require regarding any limitations imposed by law. You can reach us by email at the address below: info@spire-fundvex.com
Personal Data will be used only for the purposes specified in the Policy.
We may process Personal Data for a range of purposes, including providing you with access to the website and connecting you with third-party trading platforms (the 'Services'), as well as improving the site, protecting our rights and interests, supporting the maintenance and provision of the Services, complying with regulatory or legal obligations, and carrying out administrative and business activities to support the delivery and use of the Services.
Personal Data is also processed by us to help us better understand your preferences and needs.
To make use of key tools to protect your rights regarding Personal Data:
To help you exercise your rights, we have dedicated substantial resources. Contact Us at any time to request Personal Data about your personal data. We will amend or delete it, stop using it for specific or general purposes, and transfer the information to you or to a third party. We will do our best to accommodate your requests.
Keep your Personal Data secure:
While we cannot guarantee complete security for your Personal Data, we can assure you that we will continue to use a range of methods and techniques to help protect your Personal Data.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects about natural persons and how it processes, shares with third parties, secures, and otherwise handles that data.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we hold or can access.
The Policy defines "processing" as any activity involving the use or collection of Personal Data. This includes the management, organisation, and storage of Personal Data.
Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18 years old. We do not knowingly allow such persons to use our services. We will delete any information we discover about children as quickly as possible if we become aware of it.
2. What Personal Data Do We Hold About You?
When you use the service and channels, or visit our website, we collect Personal Data. We may ask for your Personal Data in certain cases. In other cases, we collect your Personal Data by analysing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. There is no requirement to provide personal information to the company or explain the consequences.
However, you are not required to provide Us with any Personal Data. In some circumstances, however, you may choose not to supply Us with any Personal Data. This may prevent Us from providing the Services or prevent users from accessing the website.
4. What kind of Personal Data do We collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including IP address, the date of access, the time of access and the date of access), the language you used, software crash logs, the type of browser used, as well as information about the device you used. The information collected is not private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide to Us when you connect with a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number and email address.
5. The legal basis and reasons for processing personal data
Your Personal Data is processed by the Company for the purposes set out in this section, and in line with the legal basis that applies to it.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company is able to process your Personal Data:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to meet their legitimate interests. For example, this is necessary to improve Our Services or defend legal claims.
- Processing must comply with a legal obligation.
Contact us by email for further details about the processing needed to protect legitimate interests.
Below is a list of reasons and legal grounds for which we may use the information you provide us with. Personal Data.
Scope
Legal Basis
To provide your personal information to third parties at your request to gain access to digital trading
If you request this, we may ask you for Personal Data to pass on to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is required to help answer any questions you may have about the Services.
The Company’s legitimate interests or those of a third party need to be processed.
3. To meet any legal, administrative or judicial obligation, Personal Data is processed to comply with legal requirements.
To meet legal obligations, processing is required.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, any crash or malfunction reports we collect in relation to the Services.
The legitimate interests of the Company or those of a third party must be processed.
5. To prevent fraud and misuse of Our Services
The Company's legitimate interests or those of a third party need to be processed.
6. To carry out and manage activities in line with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, etc.
The Company's legitimate interests or those of a third party need to be processed.
7. To carry out analysis, including statistical analysis
To make decisions on different issues, we use a range of analytical techniques (including statistical methods).
The Company’s legitimate interests or those of a third party need to be processed.
8. To protect our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
We may process Personal Data in order to protect our rights, interests and assets, or those of third parties, in accordance with any applicable laws, regulations or agreements and any conditions, terms or policies.
The legitimate interests of the Company or those of a third party need to be processed.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information services, and user experience analysis.
You may also ask us to share specific Personal Data relating to you with third-party trading platforms. In these cases, we will share the Personal Data you provide to Us with third-party trading platforms. The use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners. This may provide the Company with the resources it needs to enhance and improve the products and services it offers to its customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company in the group if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group) 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 services, such as those providing advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we may use are session cookies. They are temporarily downloaded to your device and remain for a short period of time until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are used to help the Website identify you as a returning user and enable you to return to the website.
Types of Cookies:
They may be used by us according to their purpose:
Cookie type
Cookies are essential
Scope
These cookies are required to let you access the features you've requested and navigate our website. Cookies are used to deliver the information, products and services you have asked us for.
They are needed for your device to download and stream data. This enables you to move around the website, use its features, and return to pages you've visited before.
Additional Information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
Cookie type
Functionality Cookies
Scope
Cookies allow us to recognise you whenever you visit our site and to save your settings and preferences.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
Cookie type
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and help improve it. They also allow Us to analyse our website.
Additional Information
Cookies store anonymous data that is not associated with any identifiable or identified natural person. They can be removed when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or have been removed
To block or remove cookies, you need to change your browser settings. Below are links to guide you through the process for some of the most widely used 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 you expect if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of personal data about You
The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer periods where permitted by applicable law, regulations, policies, or orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you agree to this, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfers of personal information to a third country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country (i.e. a country other than the one in which you reside) or to international organisations. International organisations or jurisdictions. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data subjects are able to exercise their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or international organisation which the EU Commission has determined provides adequate security for Personal Data transferred to it in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. (the "GDPR")
- The transfer is made pursuant to a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU 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 information about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk
10. Personal Data Security
We have taken appropriate organisational and technical measures to protect Personal Data. This includes preventing 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. We also 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, any Personal Data disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.
Where legal obligations or other obligations beyond our control apply, we may be required to disclose Personal Data concerning you to third parties, such as public authorities. We cannot control the security provided for your Personal Data by third parties in these situations.
Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to third-party websites
Links to third-party sites and applications are provided on the website. These applications and websites are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party website or app, we recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest that you provide them with any Personal Data.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding whether to access or use their apps. We also suggest providing them with any Personal Data.
13. Your rights regarding your personal information
You are entitled to ask us to verify the accuracy of the Personal Data collected about you, to correct any mistakes, and to delete any Personal Data that we do not require. You may also restrict certain types of processing of personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you in relation to the Personal Data you provide. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company may verify whether Personal Data about you is being processed. If it is, you are entitled to access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be provided electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request adversely affects the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.
Right to Erasure
The following reasons apply: (a) Personal Data is no longer required for the purpose for which it was collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, for reasons relating to your particular situation, to the processing of your Personal Data based on legitimate interests pursued by Us or by a third party; (e) Personal Data is unlawfully processed or (f) Personal Data must be erased to comply with a legal obligation of the company.
This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under European Union law or Member State law; or (b) to establish, exercise or defend legal rights.
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 that Personal Data be restricted, it may only be stored with your consent or in order to establish, exercise or defend legal rights, to protect the rights of another natural person, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
If the processing is carried out by automated means and is based on consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not interfere with the rights or freedoms of others.
Right to challenge
You have the right to object at any time to the use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing Personal Data, we may continue unless you show that your rights, freedoms or interests override those grounds, or where processing is required for the establishment, exercise or defence of legal rights.
Concerning direct marketing You have the right at any time to object to the processing of Personal Data concerning you.
Right to refuse consent
You may withdraw your consent for Us to process Personal Data about you at anytime. This will not affect the legality of any processing carried out on the basis of your consent before it was withdrawn.
You are entitled to lodge a complaint with the supervisory authority responsible for you.
You may lodge a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
We will provide you with the information requested under the rights set out in 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 of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Provided this does not conflict with section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.
If we have doubts regarding the identity of the person who submitted your request, the Company may ask for further information.