Privacy Policy
Last update: 21.07.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the website Zephyr Wertstead (the "Website").
The following principles will be upheld:
In the interest of transparency regarding how we process and collect your personal information:
We want you to be well-informed about how your Personal Data is used and processed. That is why we have created this website. To achieve this, we use a range of methods and procedures to provide you with relevant information about the use of your Personal Data.
Where we believe you require specific details, we will provide these at the appropriate time.
We are happy to answer any questions you may have and will offer any clarifications needed regarding limitations imposed by law. You can reach us by email at the address below: info@zefyrvartsteade.com
Personal data will only be used for the purposes set out in this Policy.
We may process your Personal Data for a range of purposes, including to provide the website and connect you with third-party trading platforms (the 'Services'), to improve the site, protect our rights and interests, to support the maintenance and delivery of the Services, to meet regulatory or legal obligations, and to carry out administrative and business activities that facilitate use of the Services.
We also process your Personal Data to better understand your preferences and needs.
To make use of the key tools available to protect your rights in relation to Personal Data:
To enable you to exercise your rights, we have dedicated resources in place. Contact us at any time to submit a request regarding your personal data. We can amend or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We are committed to accommodating your requests.
Secure your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to employ a range of methods and techniques to keep your Personal Data protected.
Our Privacy and Security Policy is complete.
1. The Scope?
This policy describes the types of Personal Data the Company collects about natural individuals, and how it processes, shares with third parties, and secures that data.
This Policy covers 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 are able to access.
The Policy defines "processing" as any operation involving the use or collection of Personal Data, including its management, organisation, and storage.
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 individuals younger than 18, nor do we knowingly permit such persons to use our services. Should we become aware that we have collected information relating to a child, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels, or visit our website, we collect Personal Data. We may ask you to provide your Personal Data in certain circumstances. 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 disclose personal information to the company, along with the consequences of this.
You are not obliged to provide us with any personal data. However, in certain circumstances, choosing not to do so may prevent us from offering our Services or restrict your access to the website.
4. What 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, data about your traffic (including IP address, date of access, time of access, and date of access), the language you used, software crash logs, the type of browser used, and information regarding the device you used. 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 connecting with an online trading platform of a third party through Us.
Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
Your personal data is processed by the company for the purposes described in this section, in accordance with the applicable legal basis.
Without a valid legal basis, the company is unable to use your personal data. The legal grounds upon which the company may process your personal data are as follows:
- You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website so that we may pass it to a third-party trading platform.
- The Company or a third party may need to process data to meet their legitimate interests — for example, to improve Our Services or to defend legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us by email for further details on the processing required to protect legitimate interests.
Below is a list of the reasons and legal grounds on which we may use the information you provide us. Personal Data.
Scope
Legal Basis
1. To share your personal information with third parties at your request in order to access digital trading
If you request this, we may ask for your Personal Data in order to pass it on to third-party companies.
You have given your consent to the processing of your personal data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is necessary to address any questions you may have regarding the Services.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
3. To meet any legal obligation or administrative, judicial, or regulatory requirement, Personal Data is processed in accordance with applicable legal obligations.
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 that we collect in relation to the Services.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary to pursue the legitimate interests of the Company or a third party.
6. To carry out and manage activities that align with the requirements of Our Services
These include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
Processing is necessary to meet the legitimate interests of the Company or those of a third party.
7. To conduct analysis, such as statistical analysis
To inform decisions on various matters, we use a range of analytical techniques (including statistical methods).
Processing is necessary to pursue the legitimate interests of the Company or a third party.
8. To protect our assets, rights and interests, as well as those of third parties, and to establish and defend legal claims
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant conditions, terms or policies.
Processing is necessary for the legitimate interests of the Company or those of a third party.
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, and user experience analytics.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will pass on the Personal Data you have provided to us to those third-party trading platforms. The use of your Personal Data will be subject to their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners. This enables the Company to access the resources required to enhance and improve the products and services it offers to its customers.
Where it is necessary to protect the rights of third parties or their assets, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, in the event that a relevant 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 advertisers on our website or analytics providers, may also be used. These companies may likewise use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve your experience, remember your preferences, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for a short period before 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 help the website identify you as a returning user and allow you to return to the website with ease.
Types of Cookies:
They may be used by us according to their purpose:
The type of cookie
Cookies are strictly necessary
Scope
These cookies are necessary to provide access to the features you have requested and to enable navigation across our website. They are used to deliver the information, products, and services you have asked for.
They are required for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you have previously visited.
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).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognise you each time 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 when you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to carry out analysis on our website.
Additional Information
Cookies store anonymous data that is not associated with any identified or identifiable natural person. They can be removed when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you will need to adjust your browser's settings. Below are links to help you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please be aware that some or all of the Website's functions and features may not work as expected if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected, as described in this Policy, or for longer periods as permitted by applicable law, regulations, or 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 sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer required.
9. Transfers of personal information to a third-party country or to an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — meaning 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 safeguard 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 individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, 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 and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in compliance 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 when transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk
10. Personal Data Security
We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosure resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.
In the event of legal or other obligations beyond our control, we may be required to disclose Personal Data about you to third parties, such as public authorities. We cannot control how such third parties manage the security of your Personal Data in these circumstances.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to us via the internet.
11. Hyperlinks to Third-Party Websites
Links to third-party websites and applications may be found on our website. These websites and applications are not under the supervision of the Company. 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 visiting any third-party website or application, we recommend reading their privacy policy before choosing to access or use their services. We also advise caution when providing any Personal Data to them.
12. Amendments to this Policy
When visiting any third-party websites or apps, we recommend reading their privacy policies before choosing to access or use them. We also advise caution when sharing any Personal Data with them.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of Personal Data collected about you, rectify any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the scope and types of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may exercise these rights by writing to the email address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. If such data is being processed, you are able to access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request is detrimental to the rights or freedoms of another person, the Company may refuse to comply or limit its ability to fulfil it.
Right to rectification
The Company is required to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purpose for which it is processed.
Right to Erasure
The following grounds apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no other legal basis for processing; (c) You object, based on reasons specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary (a) to fulfil a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you have concerns regarding the accuracy of your Personal Data, you may ask the Company to restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or in order to establish, exercise, or defend legal rights, to protect the rights of another individual, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
Where 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 right to receive your Personal Data that 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 right to erasure is not affected by the exercise of your right to data portability. The right to data portability does not infringe upon the rights or freedoms of others.
Right to object
You have the right at any time to object to the processing 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. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is not required for the establishment, exercise, or defence of legal rights, we will cease such processing.
Regarding direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent prior to its withdrawal.
You are entitled to lodge a complaint with the relevant supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect 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 your Personal Data, as set out in section 13.
We will provide the requested information in accordance with your rights under section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the complexity and volume of requests. We will notify you of any such extension, along with the reasons, within one month of receiving your request.
Unless otherwise contrary to the provisions of section 13, information provided pursuant to your rights under section 13 will be supplied free of charge. Where a request is manifestly unfounded or excessive, in particular where requests are repetitive, 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.
Where we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to verify their identity.