Privacy Policy

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 retain the information you share through the website Sereno Bitrow (the “website”).

These principles will be upheld:

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

We want you to be able to make informed decisions about the use and processing of personal data. That’s why we created this website. To do so, we use a range of methods and procedures to provide you with clear, relevant information about how personal data is used.

If we determine that specific details are needed, we will provide them at the appropriate date and time.

We are happy to answer any questions you may have and will provide any clarifications you require concerning any limitations imposed by law. You can contact us by email at the following address: info@sereno-bitrow.com

• Personal data will be used solely for the purposes outlined in the policy.

Personal Data may be processed by Us for various purposes, including to provide the website and connect you with third-party trading platforms (the 'Services'); to improve the site; to protect our rights and interests; to facilitate the maintenance and provision of the Services; to comply with legal or regulatory obligations; and to conduct administrative and business activities that support the delivery and use of the Services.

We also process your personal data to better understand your preferences and needs.

• To access essential tools to protect your rights with respect to personal data:

In order to enable the exercise of your rights, we have robust processes in place. Contact us at any time to access your personal data. We can rectify or delete it, restrict its use for certain purposes or entirely, and transfer the information to you or a third party. We will make every effort to accommodate your requests.

• Protect your personal data:

Although we cannot guarantee the absolute security of your personal data, we are committed to continuously implementing a range of technical and organisational measures to help protect your personal data.

Our privacy and security policy is thorough.

1. The Scope?

This policy explains the types of personal data the company collects about natural persons and how it processes it, shares it with third parties, secures it, and related practices.

This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly through additional information we hold or can access.

The Policy defines “processing” as any process involving the use or collection of personal data. It includes the management, structuring, and storage of personal data.

Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect or solicit information from individuals under 18, nor do we knowingly allow them to use our services. If we become aware of such information, we will delete it as quickly as possible.

2. What personal data do we hold about you?

If you access our services or channels, or visit our website, we collect personal data. We may request your personal data in certain cases. In other cases, we obtain it by analysing usage of our services and channels, including your interactions with our service channels, or by receiving your information from our third-party partners.

3. No obligation to provide personal data to the company and the associated consequences.

You are not obliged to provide us with personal data. However, in certain circumstances, choosing not to share requested information may prevent us from providing our services or may restrict users from accessing the website.

4. What types of personal data can we collect? When you visit our website, we may collect the following personal information:

This includes information about your online activity log and traffic data (such as IP address, date and time of access), the language you used, software crash logs, the type of browser used, as well as details about the device you used. The information we collect is not personal data 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 data you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.

5. The legal basis and the purposes for the processing of personal data

The company processes your personal data for the purposes outlined in this section and in compliance with the applicable legal basis.

Without a valid legal basis, the Company cannot process your personal data. The legal grounds on which the Company may process your personal data include:

• You have provided consent for the processing of your personal data for one or more purposes. This includes when you submit personal information through the website so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to process data to pursue their legitimate interests. For example, this can be necessary to improve our services or to defend legal claims
• Processing must fulfil a legal obligation.

Contact us by email for further details about the processing carried out to safeguard legitimate interests.

Below is a list of reasons and legal bases under which we may use the information you provide to us. Personal data.

6. Transfer of Personal Data to Third Parties

The company may also share personal data with third-party service providers, such as hosting and storage partners, for purposes including processing IP address information and analyzing user experiences.

You may also request that we disclose certain personal data about you to third-party trading platforms. In such cases, we will transmit the personal data you have provided to us to those third-party platforms. Their use of your personal data is governed by their own privacy policies. Your information may be shared with multiple trading platforms.

The Company may share personal data with affiliated entities or business partners. Doing so provides the Company with the resources needed to enhance and improve the products and services it offers to its customers.

In the event it is necessary to protect the rights of third parties or assets, the Company may disclose personal data to regulatory, local, or other competent authorities.

We may also share your personal data with potential investors, buyers, or lenders to the company, and with other companies in our corporate group, if a related transaction takes place (including the transfer or sale of assets belonging to the company or any company within the group) or in connection with any merger, restructuring, consolidation, or bankruptcy of the company or any other business in the group.

7. Cookies and Third-Party Services

We may use third-party services, including advertising providers on our website and analytics companies. These companies may also use cookies or other technologies.

Cookies are small text files stored on your device when you visit our website. They help collect information about your preferences and browsing behavior to enhance your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.

Some of the cookies we use are session cookies. They are temporarily stored on your device and last only for your browsing session, being deleted when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the website identify you as a returning user and make it easier for you to return to the site.

Types of cookies:

We may use them depending on their purpose:

Cookies are blocked or deleted

To block or delete cookies, adjust your browser settings. Below are links to step-by-step guides for several of the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, please note that some or all of the website's features and functions may not work as expected if this occurs.

ONLINE TRACKING NOTICE

The Company will retain your personal data only for as long as necessary to fulfill the processing purposes described in this policy, or for longer periods where required or permitted by applicable laws, regulations, internal policies, and relevant orders.

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for an additional 12 months.

We periodically review the Personal Data we hold to confirm it is no longer needed.

9. Transfers of personal data to a third country or to an international organization

Your personal information may be transferred to other countries (i.e., to a third country—meaning a country other than the one in which you reside) or to international organizations or jurisdictions. Company takes all necessary steps to protect the personal data you provide and ensures that data subjects can 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 that the European Commission has recognised as providing an adequate level of protection for personal data transferred to it, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016. (the “GDPR”)
• The transfer is carried out pursuant to a legally binding and enforceable instrument concluded between public authorities or bodies, in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the European Commission’s Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR. The clauses adopted by the European 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 details on the security measures it uses to protect your personal data when transferred to third countries or international organizations. Please email us at info@wealthwaydigital.uk

10. Personal Data Security

We have adopted appropriate technical and organizational measures to safeguard personal data. These measures help prevent accidental or unlawful destruction, loss, or alteration of personal data.

We cannot guarantee or warrant that the security of your personal data will be error-free at all times. We are also not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures due to transmission errors, unauthorised third-party access, or other causes beyond our control.

If legal requirements or other obligations beyond our control arise, we may be required to disclose your personal data to third parties, including public authorities. In these cases, we cannot control how those third parties protect your personal data.

No method of transferring personal data over the Internet is entirely secure. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to third-party websites

The website may include links to third-party websites and applications. These sites and apps are not controlled or supervised by the company. We are not responsible for the collection or processing of personal data carried out by those sites or apps. This Policy does not apply to activities performed through such sites or apps.

When visiting any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use their services. We also suggest that you provide any personal data directly to them.

12. Amendments to this Policy

This policy may be updated at any time. If we make changes, we will notify you by posting the revised policy on our website. For significant modifications, we will also seek to inform you through methods we deem appropriate and will publish an announcement on our site. Unless expressly stated otherwise, amendments will take effect upon publication of the updated policy.

13. Your rights in relation to your personal data

You are entitled to request that we verify the accuracy of the personal data collected about you, rectify any errors, and delete any personal data we do not require. You may also restrict the scope and types of processing of your personal information.

If you are an EEA resident, please refer to this page:

These rights are available to you with respect to the information you provide and your personal data. You may submit a request to exercise them by sending an email to the address below.

Access rights

The Company can verify the accuracy of the personal data processed concerning you. If so, you may 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. If requested, the data will be made available to you electronically.

The right to access personal data must not infringe the rights and freedoms of others. If a request would adversely affect another individual’s rights and freedoms, the company may refuse to comply or limit the scope of its response, in accordance with applicable law.

Right to rectification

The Company may rectify inaccurate personal data. You have the right to request that any incomplete personal data about you be rectified, taking into account the purposes of processing.

Right to Erasure

The following reasons apply: (a) the personal data are no longer needed for the purposes for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, on grounds relating to your particular situation, to processing based on legitimate interests pursued by us or by a third party; (d) the personal data have been processed unlawfully; or (e) the personal data must be erased to comply with the company’s legal obligations.

This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union 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 retained or processed with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for reasons of important public interest of the European Union or a Member State.

Right to Data Portability

If the processing is carried out by automated means and is based on your consent or 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 altered by exercising your right to data portability. The right to data portability must not infringe on the rights or freedoms of others.

Right to challenge

You have the right to object at any time to the processing of your personal data based on legitimate interests pursued by us or by a third party. This right also extends to profiling based on those legitimate interests. Unless we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, and interests, or show that the processing is necessary for the establishment, exercise, or defense of legal claims, we will stop such processing.

For direct marketing, you have the right to object at any time to the processing of your personal data.

Right to decline consent

You may withdraw your consent to our processing of your personal data at any time. This will not affect the lawfulness of processing carried out based on your consent before it was withdrawn.

You have the right to lodge a complaint with your supervisory authority.

You may lodge a complaint with the supervisory authority established by a Member State to safeguard individuals' fundamental rights regarding the processing of personal data within the European Union.

European Union and Member State laws may restrict your rights regarding your personal data, as outlined in Section 13.

We will provide the requested information in accordance with your rights under 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 complexity and volume of requests. Within one month of receiving your request, we will notify you of any extension and the reasons.

As long as it does not conflict with the provisions of Section 13 of the law, the information you request, pursuant to your rights under Section 13, will be provided free of charge. If a request is unfounded or excessive, particularly if made repeatedly, we may charge a reasonable fee to cover the administrative costs of supplying the information or carrying out the requested action. We may also decline to act.

If we have any doubts regarding the identity of the person who submitted your request, the company may ask for additional information.