Privacy Policy

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

Barclay Valnor collects and stores data necessary for your trading activity. Our Privacy Policy outlines how we gather and maintain this information.

Our approach is guided by the following principles:

• To ensure complete transparency in how we collect and store your personal data:

We're committed to helping you understand how we collect and use your data, so you can make informed decisions. We maintain clear guidelines and processes for handling all data through this website, and our policy sets out the specific methods we use. You remain in control of your information.

We'll always keep you informed promptly whenever there's something you need to know. Transparency is fundamental to how we operate.

Our experienced team is always available to answer any questions you may have about our processes and our legal obligations under the laws of United Kingdom. Please get in touch with us at: info@barclay-valnor.com

• We do not use your personal data for any purpose other than those outlined in our Privacy Policy.

We may process your personal data for several purposes, including the essential operation of Barclay Valnor services, connecting trader-members with third-party trading platforms, and maintaining and improving our website functions. We also process data to protect our rights, meet regulatory and legal obligations, and support the administrative and business functions necessary to deliver our services to you.

To provide you with better services tailored to your preferences and needs, Barclay Valnor uses your personal data.

• To protect your personal data and safeguard your rights, you'll need access to essential security tools.

You can contact us at any time to access all your personal data. We can also modify or delete it as required, and we support requests to transfer your data to you or a designated third party. We provide this service to help you exercise your privacy and data control rights.

• Protect your personal information:

Our security systems employ banking-grade measures of the highest standard. While we cannot guarantee absolute security, we remain committed to continuously enhancing our systems and strengthening our protective measures to the fullest extent possible.

We maintain comprehensive privacy policies and employ the highest level of security systems to protect your data.

1. The Scope?

This policy sets out our procedures for collecting, processing and sharing personal data.

Our policy terms apply to all identifiable or identified natural persons. This includes any individual who can be identified, or has been identified, in connection with data entrusted to us or that we can access and combine.

The processing of data, as outlined in our Privacy Policy, refers specifically to the storage, management and organisation of your personal data.

We do not collect or request any information from individuals under the age of 18, nor do we permit anyone under 18 to use our platform. Should we discover any user or information relating to a person under 18, it will be deleted immediately.

2. What personal information do we collect and store?

When you register with us, we collect the necessary personal information to enable you to use our services. We may also request additional details to verify account ownership when required. To ensure we maintain the highest quality of service, we analyse data relating to how you use our platform and services provided by our third-party partners.

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

While providing your information is entirely voluntary, failing to do so may result in limitations on the services we can offer and could restrict your access to 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 personally identifiable information about you. However, we do collect data such as your account activity, IP address, and access timestamps. For maintenance, security, and support purposes, we retain system crash reports, browser details, and device information associated with your account. We also record your account's language preference.

Regarding personal data collection, we only accept and retain information that you voluntarily provide when connecting with a third party trading platform through us.

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

Why does the company require my personal data, and is it legal for them to do so?

We collect, store, and process your personal information solely for the purposes outlined in this Policy. All such use and processing complies with applicable data protection laws in United Kingdom.

The company can only handle, process, and transmit your data in accordance with applicable data protection laws in United Kingdom. The legal basis for doing so is as follows:

• You have consented to the storage and processing of your personal data by the company. When you submit your information to us, you authorise us to transfer that data to the relevant third-party trading platform. You have given your consent for your personal data to be processed for one or more specified purposes.
• To improve our services, establish or defend legal claims, and pursue our legitimate interests, we may need to store and process your personal data.
• To comply with legal requirements, we process your data accordingly.

If you'd like to learn more about our data processing practices, please feel free to contact us via email.

Below, you will find a detailed breakdown of how we may use your personal data, along with the legal basis for each use.

6. Sharing Your Personal Data with Third Parties

To improve our services, including IP address storage, user surveys, and analytics, we may share anonymised personal data with trusted third-party service providers.

At your request, we may share your personal data with third-party service providers, including digital trading platforms. When we do, their respective privacy policies will govern how your data is used.

To enhance our services and better support our clients, we may share personal information with our affiliates and partner companies.

We may disclose your data to relevant legal or regulatory authorities as required by law, or to protect the rights and assets of our company and our partners.

In the event of a critical business transaction—such as a company sale, investment pursuit, or loan application—we may share relevant data in a legally compliant manner. This also applies to company mergers, restructuring, consolidation, or bankruptcy proceedings, as required by law.

7. Cookies and Third-Party Services

To improve site analytics and support our advertising partners, we may use cookies and similar technologies in accordance with applicable law and industry standards.

Cookies are small files stored on your device when you visit our website. We use them to gather information about your browsing behaviour and preferences, allowing us to personalise your experience and remember your settings. This enables us to tailor our service offerings to suit your needs. We also use cookies for site analytics and statistical analysis to inform our strategic planning.

We use two main types of cookies on our site. Session cookies are temporary and stored only during your visit—they're automatically deleted when you close your browser. Persistent cookies remain in your browser after you leave, allowing us to recognise you as a returning visitor and improve your experience on the site.

Types of cookies:

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

Cookies have been cleared or disabled

If you wish to delete or block cookies, you can do so through your browser settings. Follow the links below for step-by-step instructions on how to manage cookies with the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Disabling cookies may prevent certain features and functionality from working as intended on this site.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to fulfil the purposes described in this policy. We may store it for longer periods in accordance with applicable laws, regulations, and our company policies.

Your personal data may be shared with third-party trading platforms at your request and discretion for a period of 12 months. After this initial 12-month period, your data will continue to be shared for a further 12 months, subject to your consent.

We regularly review all personal data we hold to determine whether it remains necessary.

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

Where necessary for service delivery and security purposes, your personal data may be transferred to third countries and international organisations using robust security protocols. We maintain the highest standards of data protection to safeguard your information and ensure you retain full legal rights and remedies in all circumstances.

All residents within the European Economic Area (EEA) are protected by comprehensive data protection and safeguard regulations.

• Data transfers always take place within the legal jurisdiction and competency of the EU, in accordance with standard data protection protocols as outlined in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
• Any transfer of data between public entities or authorities is conducted in accordance with Article 46(2) and constitutes a legally binding and enforceable agreement.
• We comply with the European Commission's Standard Contractual Clauses under Article 46(2)(c) of the GDPR, which govern our data transfer practices. You can review the full clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For further details on the security measures we use to protect your personal data during transfers to third countries, please contact us at info@wealthwaydigital.uk

10. Personal Data Protection

Your personal data is protected by the highest level of technical and organisational safeguards, following industry best-practice procedures. These measures effectively prevent unauthorised access, accidental data loss, and any unlawful alteration or destruction of your information.

Whilst we implement rigorous data protection measures in accordance with legal requirements, we cannot guarantee that personal data will remain error-free in all circumstances. Consequently, we cannot be held responsible for any unauthorised disclosure, loss, or consequential damage to personal data, including incidents beyond our control such as transmission errors, unauthorised third-party access, or similar occurrences.

Where we receive legally binding requests from regulators or legal authorities, we may be required to disclose your personal data to them. Once your data has been shared in response to such legal requirements, we have no control over how those authorities subsequently handle, store, or protect that information.

While we take comprehensive measures to protect your information, data transmitted over the internet, including personal details, carries inherent risks and cannot be guaranteed as completely secure. The Company cannot warrant absolute security for any data transmitted online.

11. Third-party website links

This website contains links to third-party applications and websites that are not affiliated with us and are not under our control. Please be aware that our privacy policy does not apply to these external sites. They operate under their own data protection procedures and policies, and we are not responsible for their practices. Please use these links at your own discretion.

Always review the privacy policy of any company or service before providing personal data on their website. Check that their data collection, usage, and processing practices align with your preferences and requirements. Share any personal information directly with the service provider only.

12. Policy Amendments

We reserve the right to update or modify our policy at any time. Changes will be communicated to you through our website and other appropriate channels. The updated privacy policy will be posted on the website and shall take effect immediately upon publication, unless otherwise specified.

13. Your personal data rights

You maintain full control and final authority over your personal data, including the ability to verify its accuracy, correct any errors, and choose to delete or restrict the scope and nature of any data processing we undertake.

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

Your personal data is protected under the rights described herein. You can exercise these rights at any time by emailing the address below.

Accessing Your Rights

If the personal data you've provided is accurate, you can access it at any time. Any personal data we process is accessible and verifiable by us.

You can request your personal data at any time for verification purposes, and we will provide it to you in electronic format. If you request additional copies beyond the first one provided, a reasonable administrative fee may apply.

The company reserves the right to refuse or restrict access to personal data where doing so is necessary to protect the rights and freedoms of others, in accordance with applicable law and our privacy policy.

Right to Correct Errors

You or the Company may correct any errors or omissions in your personal data to ensure it can be processed accurately.

Erasure Rights

You have the right to request deletion of your personal data in the following circumstances: 1) if your personal data has been processed without your consent or outside legal boundaries; 2) if you request removal and the Company has no legal obligation to retain that data; 3) if you withdraw your consent to any data processing by us, even where such processing is lawful and serves our legitimate interests or those of a third-party provider; and 4) if we are legally required to delete your data.

The right to deletion may not apply where legal obligations under EU law or member state legislation require data retention, or where data is necessary for the establishment, exercise, or defence of legal claims.

Right to Restrict Data Processing

You have the right to request that we limit how we process your personal information if you believe it contains inaccuracies.

When you request that your personal data usage be restricted, we will delete it except in the following circumstances: 1) where the law of the European Union or any Member State requires us to retain it. 2) With your consent, if retention is necessary to defend or exercise legal claims. 3) To protect the rights of another individual.

Right to Data Portability

You have the right to access and review any personal data you've provided, provided you consented to its collection and processing by automated systems.

You have the right to request the transfer of your personal data to another company or organisation, provided it is technically feasible. This does not affect your right to request deletion of your data. However, this right cannot be exercised where doing so would compromise the rights or freedoms of another individual.

Your right to challenge data processing

Regardless of the Company's right to pursue legitimate interests—whether our own or those of a third party service provider—you have the right to object to processing and request that it stops. However, this right does not apply where there is a compelling legal basis to continue processing, such as to defend against or exercise legal claims. In such circumstances, we may continue to process your personal data.

You can request at any time that your personal data is not processed for direct marketing purposes.

Right to Withdraw or Decline Consent

You may withdraw your consent to our processing of your personal data at any time with immediate effect, where possible. Please note that this does not affect any processing that took place before your withdrawal.

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

If you believe your rights and freedoms have been infringed in relation to the processing of your personal data, regulatory and supervisory authorities have been established throughout the European Union to address such concerns. You may lodge a complaint with these authorities at any time.

Section 13 outlines circumstances in which your personal data rights may be limited under European Union law or the laws of EU Member States.

When you request access to your personal data, we will provide the information you've requested as outlined in Section 13 of this policy. We may extend this period by up to two months if necessary, depending on the volume of requests and the complexity of your enquiry. Should an extension be required, we will notify you of the revised deadline within one month of receiving your request.

We'll send you the information you've requested electronically at no cost, unless prohibited by law or the terms outlined in Section 13. We reserve the right to charge a reasonable fee or decline requests that we consider frivolous, excessive, or repetitive.

We reserve the right to request additional proof of identity where we have reasonable grounds to doubt the identity of the person making a data access request, in accordance with data protection and security requirements.