Privacy Policy

We (referred to as “we”, “us”, or “our”) are committed to protecting your personal information and your privacy.

This Privacy Policy explains how we collect and store the information you provide through the Sunfort Portdex website (the “Website”).

We will defend these principles:

• To be transparent about the collection and processing of your personal information:

We want you to be able to make informed choices about the collection, use, and processing of your personal data. This is why we’ve created our website—to explain what we do and how we do it. To support this, we use a variety of methods and procedures to give you clear, accessible, and relevant information about how personal data is collected, used, and managed.

If we determine that you need specific information, we’ll provide it to you at the appropriate date and time.

We are available to answer any questions you may have and to provide any clarifications you need regarding limitations imposed by law. You can reach us by email at the address below: info@

• We will use personal information solely for the purposes set out in this policy.

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

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

• Make use of essential tools to protect your rights in relation to personal data:

To help you exercise your rights, we have extensive resources. Contact us at any time to request access to your Personal Data. We can correct or delete it, or stop using it for specific purposes or altogether. We can also transfer your information to you or to a third party. We will endeavour to accommodate your requests.

• Protect your personal data:

While we cannot guarantee the absolute security of your personal data, we guarantee we will continue to apply a range of security measures and technologies to help ensure your personal data remains protected.

Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of personal information the company collects about individuals, how it is processed, shared with third parties, and the measures used to keep it secure.

This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through the combination of other information we hold or can access.

The Policy defines “processing” as a process that involves 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 years of age. We do not knowingly collect personal information from individuals under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we have collected information about a child, we will delete it from our records as soon as reasonably practicable.

2. What personal information do we hold about you?

When you use our services or channels, or visit our website, we collect personal data. In some cases, we may ask you to provide personal data. In others, we collect it by analysing how our services and channels are used or by receiving information from our third-party partners.

3. No obligation to disclose personal information to the company and the consequences of not doing so.

However, you are not required to provide us with any personal data. In some circumstances, you may choose not to share personal data. Doing so may limit our ability to provide our services or could prevent users from accessing the website.

4. What types of personal information do we collect? When you visit our website, we will collect the following personal information:

This includes details of your online activity log, traffic data (including IP address and the date and time of access), the language you use, software crash logs, the type of browser used, and information about the device you utilised. This information is not personal and cannot be used to identify you.

Personal Data We receive from you: Any personal data you voluntarily provide to Us when you connect through Us to a third-party online trading platform.

Personal information you provide specifically to third-party platforms to facilitate trading: this information may include your full name, address, phone number and email address.

5. Legal basis and reasons for processing personal data

The company processes your personal data for the purposes set out in this section, in accordance with the applicable legal basis.

Without a valid legal basis, the company is not permitted to use personal data about you. The legal grounds on which the company is permitted to process personal data about you are:

• You have consented to the processing of your personal data for one or more purposes. This applies when you provide personal information via the website so we can transfer it to a third-party trading platform.
• The Company or a third party may need to process personal information to pursue their legitimate interests. For example, to improve our services or defend against legal claims.
• Processing must comply with a legal obligation.

Please contact us via email for more information about the processing required to protect legitimate interests.

Below is a list of reasons and legal bases explaining how we may use the information you provide. Personal data.

6. Disclosure of Personal Data to Third Parties

The company may also share personal data with third-party service providers that support us, such as hosting and storage providers, for purposes like processing IP addresses and analysing user experiences.

You may also ask us to share specific personal information about you with third-party trading platforms. In these cases, we will provide the personal information you have given us to those third-party platforms. The handling of your personal information will be governed by their privacy policies. Your personal information may be shared with multiple trading platforms.

The Company may share personal information with related entities and business partners. This helps the Company access the resources needed to enhance and improve the products and services it provides to customers.

Where necessary to safeguard the rights of third parties or assets, the Company may disclose personal data to regulatory, local or other official authorities.

We may also share your personal data with potential investors or buyers, or with lenders to the company or any other company in our corporate group, if such a transaction occurs (including the transfer or sale of assets belonging to the company or any other group company), or as part of any merger, restructuring, consolidation, or insolvency of the company or any other business within the group.

7. Cookies and third-party services

We may use third-party services, such as advertisers on our website or analytics companies. These providers may also use cookies or similar technologies.

Cookies are small text files stored on your device whenever you visit or use this website. They collect information about your preferences and browsing activity to enhance your experience, remember your settings, and customise the products and services you see. Cookies are also used for statistical and analytical purposes.

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

Types of cookies:

We may use them according to their purpose:

Cookies are blocked or deleted

To block or delete cookies, adjust your browser's settings. The links below provide guidance for several 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 expected if this occurs.

ONLINE TRACKING NOTICE

The Company will retain your personal data for as long as necessary to achieve the purposes for which it is processed, as described in this policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.

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

We routinely review the Personal Data we hold to ensure it is no longer required.

9. Transfers of personal information to a third country or to an international organisation

Your personal information may, from time to time, be transferred to other countries (i.e. your personal data may be transmitted to a third country (i.e. a country other than the one in which you reside)) or to international organisations, jurisdictions, or bodies. The Company takes all necessary and appropriate measures to protect the personal data you provide and ensures that individuals 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 determined ensures 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 made under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46 (2) (a).
• The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission 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 of the security measures it uses to protect your personal data when it is transferred to overseas recipients or international organisations. Please email us at info@wealthwaydigital.uk

10. Security of Personal Information

We have implemented appropriate organisational and technical measures to protect personal data. These measures help prevent 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 error-free. Nor are we 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 resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.

Where we are subject to legal requirements or other obligations beyond our control, we may be required to disclose your personal information to third parties, including public authorities. In these circumstances, we cannot control how those third parties protect your personal information.

Transmitting personal data over the Internet is never completely risk-free. The Company cannot guarantee the security of any personal data you send to us online.

11. Hyperlinks to websites operated by third-party providers

Links to third-party websites and applications may be available on this site. These sites and apps are not under the company's control. We are not responsible for the collection or processing of personal information by those websites or applications. This Policy does not apply to activities conducted through such sites or apps.

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

12. Amendments to this Policy

This Policy may change at any time. If we update it, we will notify you by posting the revised policy on our website. When we make significant changes, we will also seek to notify you through methods we consider appropriate and will publish a notice on our website. Unless stated otherwise, any amendments take effect once the revised policy is published.

13. Your rights in relation to your personal information

You are entitled to request that we verify the accuracy of the personal information we hold about you, correct any errors, and delete any personal information we do not need. You may also limit certain types of processing of your personal information.

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

These rights are available to you in connection with the personal information you provide to us and we hold. You can request to exercise your rights by sending an email to the contact address provided below.

Access rights

The Company can confirm whether personal data concerning you are being processed. If so, you can access your personal data.

We can provide an electronic copy of the personal information we currently process and may charge a reasonable fee for any additional copies. We will make the data available electronically on request.

The right to access personal data must not infringe the rights and freedoms of others. If a request would adversely affect another person’s rights or freedoms, the company may refuse to comply or limit its ability to do so.

Right to rectification

The Company is authorised to correct inaccurate personal information. You have the right to request that any incomplete personal information about you be corrected, having regard to the purpose of processing.

Right to Erasure

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

This right is not applicable where processing is necessary (a) to comply with a legal obligation imposed by, or arising 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 processing of your personal data.

If you request that your personal data be restricted, it may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a member state.

Right to Data Portability

If the processing is performed by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to access and 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 this is technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to transfer data does not infringe on the rights or freedoms of anyone else.

Right to challenge

You may object at any time to the processing of your personal data where it is based on legitimate interests pursued by the company or a third party. This also includes any profiling that relies solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your personal data that override your rights, freedoms or interests, or that the processing is necessary for the establishment, exercise or defence of legal claims, we may continue the processing.

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

Right to withhold consent

You may revoke your consent for us to process personal data about you at any time. This won’t affect the lawfulness of any processing that was dependent on your consent prior to its withdrawal.

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

You may lodge an appeal with a supervisory authority established by a Member State to protect the fundamental rights of individuals concerning the processing of personal data within the European Union.

The laws of the European Union and its Member States may restrict your rights in relation to your personal data, as detailed in section 13.

We will provide you with the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended to a maximum of two months if required, depending on the nature of your request and the volume of requests. We will notify you within one month of receiving your request of any extension and the reasons for it.

Provided it does not conflict with section 13 of the Act, information you request under your rights in section 13 will be provided free of charge. If a request is unfounded 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 concerns about the identity of the person submitting the request, we may request further information to confirm your identity and safeguard your privacy.