Privacy Policy

Protecting your personal data and assets is our highest priority. We are fully committed to safeguarding them.

Trzon Gainlux collects and retains data necessary for your trading activities. Our methods for collecting and storing this information are outlined in the Privacy Policy below.

Our policy is grounded in the following principles:

• To ensure full transparency regarding our processes for the collection and storage of your personal data:

Our goal is to ensure you understand how we collect and process data so you can make informed decisions. We maintain clear guidelines and processes for handling data on this website. Our policy outlines the specific methods we use so you have clear, concrete information about its use. You are in the driver's seat.

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

Our knowledgeable team is always available to answer any questions you may have regarding any aspect of our processes, including our obligations under Polska law. You can contact us at: info@trzon-gainlux.com

• We do not use personal data for any purpose other than what is described in our Privacy Policy.

We may process personal data for purposes such as ensuring the proper operation of Trzon Gainlux services and connecting trader members with third-party trading platforms. We may also need this data to maintain and enhance website features and services, protect our rights, and fulfill regulatory or other legal obligations. Finally, we process data as necessary to provide administrative and other business functions related to the Services we deliver to you, the client.

To provide better services tailored to your preferences and needs, Trzon Gainlux processes personal data.

• To ensure you can effectively use the essential tools required to protect your personal data and fully uphold your rights in this regard:

You can contact us at any time to request access to all of your personal data. We can also correct or delete it where appropriate. In addition, upon request, we can facilitate requests to transfer that data to you or to a designated third party. We provide these services to help you fully exercise your rights to privacy and control.

• Secure your personal data:

Our security systems meet the highest standards, employing banking‑grade safeguards. While a 100% guarantee is not feasible, we remain committed to continually enhancing our systems to the highest possible level and strengthening the protections we already have in place.

We uphold a detailed and comprehensive privacy policy and top-tier security systems.

1. The Scope?

This policy outlines our procedures for the collection, processing, and sharing of all data relating to natural persons.

The terms of our policy apply to all natural persons who are identifiable or already identified. This includes any individual who can be, or has been, identified in relation to data entrusted to us, or to which we have access and may process or combine.

As defined in the Privacy Policy, data processing specifically refers to the storage, management, and organization of personal data.

We do not collect, nor do we seek to collect, any information about individuals under the age of 18. We also prohibit individuals under 18 from using our platform for any purpose. If we discover any user or information relating to a person under 18, it will be deleted immediately.

2. What personal data do we retain?

When you register with us, we collect the personal data needed to enable your use of our services. Where required, we may also request personal data to verify account ownership, for example. To maintain and continually improve service quality, we collect and analyse data about your use of our platform and that of our third-party partners.

3. You are under no obligation to provide the company with your personal data.

Although you are not required to share your data with us, declining to do so may limit the services we can provide. It may also result in restrictions on your use of 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 information that can personally identify you. We do, however, gather details such as your account activity, users’ IP addresses, and the dates and times of access. For maintenance, security, and support, we retain system crash reports, browser details, and the type of device used to access your account. We also record the language associated with your account.

Regarding personal data, we collect and retain only the information you consent to share with us when you connect to 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.

5. Why does the company need my personal data, and is it lawful for them to process it?

The company's collection, storage, and processing of your personal information is solely for the purposes set out in the Policy. All such uses and processing comply with applicable laws in Polska.

The company will not handle, process, or transmit your data except in accordance with the applicable laws of Polska. The legal bases for doing so are as follows:

• You have consented to the company storing and processing your personal data. By submitting your information to the company, you authorize us to transfer it, where appropriate, to the relevant third-party trading platform. You have also agreed to the processing of your personal data for one or more purposes.
• To improve its services, establish or defend legal claims, and pursue legitimate interests, among other purposes, the company may need to store and process your personal data.
• Data processing is necessary to meet legal obligations.

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

Below you will find a list of the specific purposes for which we may process your personal data, along with the legal basis.

6. Sharing of Personal Data with Third Parties

To store and process IP addresses, conduct user surveys and analyses, and provide 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 services. In such cases, the processing of your data will be governed by those companies' privacy policies. This may include multiple digital trading platforms.

To better serve our clients and enhance our overall services, the company may share personal data with its affiliates and partner companies.

Where required by law, or to safeguard the company’s rights and assets and those of third‑party partners, we may disclose data to the relevant legal or regulatory authorities.

In connection with critical business transactions—such as a company sale, investment, or loan—relevant data may be shared in a lawful and appropriate manner. This also applies in the event of any merger, restructuring, consolidation, or bankruptcy, in accordance with applicable law.

7. Use of Cookies and Third-Party Services

For site analytics and in collaboration with advertising partners, we may use cookies and similar technologies, as permitted by law and in line with standard practice.

Cookies—small data files stored on your device when you visit a website—help collect information about your browsing behaviour, preferences, and interactions. They are used to personalise and enhance your experience, allowing us to remember your settings and tailor our service offerings accordingly. Cookies are also employed for site analytics and to compile statistics used for strategic planning.

Broadly speaking, the site uses two types of cookies. Session cookies are stored only for the duration of your browsing session and are removed when you close your browser. The others are persistent cookies, which remain in your browser even after your session ends. These cookies help the site recognize you when you return and make it easier for you to use the site.

Types of cookies:

Cookies may be used as necessary, consistent with their intended purpose:

Cookies have been blocked or removed

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

• firefox
• Microsoft Edge
• Google Chrome
• safari

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

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to perform the processing activities described in this policy. It may be kept longer to comply with applicable laws, regulations, and company policies.

At your request and discretion, your personal data will be shared with third-party trading platforms for a 12-month period. Once that period ends, and with your consent, the data will be shared for a further 12 months.

Our operations involve regularly reviewing all personal data to determine whether it is still necessary.

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

When required to deliver our services and/or for security reasons, personal data may be transferred to third countries (countries other than your own) and to international organizations, subject to robust security safeguards in place. We apply the highest standards of data protection to safeguard your information and ensure you can access legal remedies and rights in all situations.

Within the EEA (European Economic Area), all residents are protected by data protection laws and safeguards.

• All data transfers take place under the EU’s 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 transfers of data between public entities or authorities are conducted pursuant to Article 46(2). This arrangement is legally binding and enforceable.
• The European Commission’s Standard Contractual Clauses, under Article 46(2)(c) of the GDPR, set out the conditions for data transfers, and such transfers are conducted accordingly. 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 security measures the company uses to protect your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is protected with the highest-level technical and organisational measures, in line with industry best practices. These measures help prevent the destruction of data caused by unlawful or accidental events, as well as its loss or alteration.

Although we apply the highest levels of care and legally mandated best practices for data protection, it is not possible to guarantee in every circumstance that your personal data will remain entirely free of error or risk at all times. Accordingly, we cannot be held liable for any disclosure of personal data, or for incidental, intangible, or consequential damage. This includes situations beyond our control, such as disclosures resulting from transmission errors, unauthorized third-party access, system failures, or other similar events.

When legally compelled by regulators or other authorities, we may be required to disclose your personal data to them. After disclosure under such legal obligations, we cannot control how those authorities handle, store, or protect your data.

Any information sent over the internet, including personal data, carries a risk of interception and therefore cannot be guaranteed to be completely secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

On this website, you may encounter links to third-party applications and websites. Please note that these parties are not our affiliates, are not controlled by the company, and our privacy policy does not apply to them. They maintain their own procedures and priorities for collecting and processing personal data, and we are not responsible for such activities. Use at your own discretion.

Always review the privacy policy of any company or service when visiting their website before sharing personal data. Confirm that their data collection, use, and processing policies align with your preferences and priorities. Whenever you choose to share data, do so directly with the service provider.

12. Policy Amendments

We reserve the right to modify or update our policy at any time. We will notify you of any changes via this website and other appropriate channels. The latest version of our Privacy Policy will be posted here and, unless stated otherwise, will take effect immediately upon publication.

13. Your data protection rights

You have full control and the final decision over the use of all personal data, including verifying its accuracy, correcting errors, and choosing at any time to delete it or restrict the scope and nature of our data processing.

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

Your personal data is protected by the rights described herein. You can immediately exercise these rights by sending an email to the address below.

Accessing Your Rights

If the personal data you have provided to us is accurate, you may access that data at any time. Any of your personal data that we process is accessible to us and, as such, verifiable.

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

Rights granted under applicable law and this Privacy Policy must not infringe on the rights of others. The Company may refuse or restrict access to personal data where such access would violate the rights or freedoms of others.

Right to Rectify Inaccuracies

Any inaccuracies in your personal data, whether due to omissions or incorrect information, may be corrected by you or by the Company to ensure proper processing.

Erasure Rights

You have the right to request the deletion of your personal data under the following circumstances. 1) Your data has been processed without your consent or beyond lawful grounds. 2) You request its removal and the Company has no legal obligation to retain it. 3) You no longer consent to any processing by us, even if lawful and based on our legitimate interests or those of a third-party provider, and finally 4) we are legally required to delete your data.

The right to erasure may be overridden by legal obligations under EU law or the laws of any member state. Likewise, if data is needed for the establishment, exercise, or defence of legal claims, it may be retained.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal data if you believe it contains inaccuracies.

If you request that the use of your personal data be restricted, it will be deleted except in the following cases: 1) where EU or Member State law precludes deletion. 2) With your consent, where necessary to establish, exercise, or defend legal claims. 3) To protect the rights of another natural person.

The Right to Data Portability

You have the right to access and review any personal data you have provided, if you have consented in any way to its collection and its processing is carried out by automated systems.

You have the right to request the transfer of any or all of your personal data to another company or organisation, where this is technically feasible. Exercising this right does not affect your right to have your data deleted. It cannot be used where doing so would infringe the rights or freedoms of another natural person.

Right to object to data processing

Without prejudice to the Company’s right to pursue its 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 need to continue processing, including to establish, exercise, or defend legal claims. In such cases, we may continue processing your personal data.

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

Right to Withdraw or Refuse Consent

You have the right to withdraw your consent to our processing of your personal data at any time, with immediate effect where feasible. This does not apply retroactively to processing carried out before you withdrew consent.

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

If you believe your rights and freedoms have been violated in connection with the processing of your personal data, EU Member States have designated regulatory and supervisory authorities for this purpose. You may file a complaint with these authorities at your discretion.

Section 13 outlines the circumstances under which your personal data rights may be restricted under applicable European Union or Member State law.

Once we receive your request concerning your personal data and its processing, we will provide access to the information you requested, as outlined 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 inquiry. If an extension is required, we will notify you within one month of receiving your request.

Requested information will be provided to you electronically at no cost, unless doing so would contravene the law or the requirements of Section 13. We may charge a reasonable fee or decline a request if it is considered unfounded, excessive, or repetitive.

We reserve the right to request additional proof of identity whenever there is reasonable doubt about the individual submitting a personal data request, to safeguard data protection and security.