Privacy Policy

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

Fulgor Fundex collects and retains data essential to your trading activities. The methods used to collect and store this information are detailed in the following Privacy Policy.

Our policy is grounded in the following principles:

• With the aim of ensuring full transparency about how we collect and store your personal data:

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

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

Our knowledgeable team is always available to answer any questions you may have about any aspect of our processes, including our obligations under the laws of Portugal. You can reach us at: info@fulgor-fundex.com

• We will not use personal data for any purpose other than as set out in our Privacy Policy.

We may process personal data for the following purposes: supporting the proper operation of Fulgor Fundex services and facilitating connections between trader-members and third-party trading platforms. We may also process data to maintain and enhance website functions and services; protect our rights; and comply with regulatory or other legal obligations. Finally, where this data is required, we process it to deliver administrative and other business functions related to the Services provided to you, the client.

To deliver better services tailored to your preferences and needs, Fulgor Fundex processes personal data.

• To ensure you are able to use essential tools to protect your personal data and safeguard your rights in this regard:

You may contact us at any time to access the full set of your personal data. We can modify or delete it as needed. We can also accommodate requests to transfer your data to you or to a designated third party. We offer these services and support to help you fully exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems meet the highest standards, employing bank-grade security measures. While no system can be guaranteed 100% secure, we are committed to continuously enhancing our systems and reinforcing the safeguards we have in place.

We maintain a detailed and comprehensive privacy policy and the highest-level security systems.

1. The Scope?

In this policy, we set out our procedures for collecting, processing, and sharing any and all data relating to natural persons.

Our policy applies to all natural persons who are identifiable or already identified. This includes any individual who can be, or has been, identified based on data entrusted to us or data we can access and/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, or seek to collect, any information about individuals under 18. We also do not permit individuals under 18 to use our platform for any purpose. If we become aware of any user under 18 or any information relating to a person under 18, we will delete that information immediately.

2. What personal data do we retain?

When you register with us, we collect the personal data necessary to enable your use of our services. Where required, we may also request personal data to verify account ownership, for example. To improve and maintain the highest quality of our services, we collect and analyse information about how you use our platform and its services, as well as those of our third‑party partners.

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

While you are under no obligation to provide your data, choosing not to do so may result in limitations on the services we are able to offer. It may also result in your access to our platform being restricted.

4. What personal data do we collect? When you visit our website, we may collect the following personal data:

We do not collect any data that could personally identify you. However, we do collect information such as your account activity, IP addresses, and the date and time of access. For maintenance, security, and support purposes, we retain system crash reports, browser details, and the type of device used to access your account. We also record the language configured for your account.

Regarding personal data collection, we only collect and retain the information you consent to provide when you connect with a third-party trading platform through us.

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

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

The company collects, stores, and processes your personal information solely for the purposes set out in this Policy. All such uses and processing are carried out in compliance with the applicable laws in Portugal.

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

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

If you would like more information about the data processing our company is legally required to perform, please feel free to contact us by email.

Below is a list of the specific purposes for which we may process your personal data, together with the relevant legal bases.

6. Sharing of Personal Data with Third Parties

To store and process IP addresses, conduct user surveys and analyses, and deliver related services, the company may share anonymised personal data with third-party service providers.

At your request, we may share certain personal information you provide with third-party services. In such cases, the handling of your data will be subject to that company’s privacy policies. This may include various digital trading platforms.

To improve services for our clients and enhance our overall service quality, the company may share personal information with its affiliates and partner companies.

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

In the event of a significant corporate transaction—such as the sale of the company, seeking investment, or obtaining a loan—we may share relevant data in a lawful and appropriate manner. This also applies in the case of any company 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 from time to time use cookies and other similar technologies, in accordance with applicable laws and recognized industry practices.

Cookies – small data files stored on your device when you visit a website – are used to collect information about browsing behaviour, preferences, and more. Their purpose is to personalise and enhance your user experience. They allow us to remember your settings and preferences and to tailor our service offerings accordingly. We also use these cookies for site analytics and to compile statistics for strategic planning.

Broadly, there are two types of cookies used on this site. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. The other type is persistent cookies, which remain in your browser even after your session ends. These help the site recognise you as a returning visitor and make it easier for you to use the site.

Types of cookies:

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

Cookies have been blocked or removed

If you want to delete or block cookies, you must do so through your browser settings and preferences. Follow the links below for step-by-step instructions on how to manage this in the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some processes and site features from operating as intended.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to carry out the operations described elsewhere in this policy. It may be kept for longer to comply with local laws, regulations, and company policies.

Upon your request and at your discretion, your personal data will be shared with third-party trading platforms for 12 months. When that period ends, and with your consent, this data will be shared for an additional 12 months.

Our processes include routinely reviewing all personal data to determine whether it remains necessary.

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

Where necessary to provide our services and/or for security reasons, personal data may be transferred to third countries (outside your country of residence) and to international organizations using robust security protocols. We apply data protection measures at the highest possible level to safeguard your information and ensure you can exercise your legal rights and remedies in all cases.

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

• Data transfers are always conducted under the EU’s legal jurisdiction and competence, in accordance with the standard data protection protocols 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 data transfers between public entities or authorities are conducted in compliance with Article 46(2). This is a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, provided for in Article 46(2)(c) of the GDPR, establish the conditions for data transfers and are applied accordingly. The Clauses can be accessed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For more details about the company’s specific security measures protecting your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is safeguarded through the highest level of technical and organisational measures, in accordance with gold-standard procedures. These measures effectively prevent the unlawful or accidental destruction, loss, or alteration of data.

Although we apply the highest levels of care and gold‑standard procedures for data protection, as required by law, it is not possible to guarantee in every circumstance that your personal data will be maintained error‑free. Accordingly, we cannot be held liable if personal data is disclosed or suffers damage of an incidental, intangible, or consequential nature. This includes situations beyond our control, such as disclosure arising from transmission errors, unauthorised third‑party access, or any other cause of this kind.

If we receive a legally binding request from regulators or legal authorities, we may be required to disclose your personal data to those authorities. Once we share data under a legal obligation, we cannot control how those bodies handle, store, or protect your personal data.

Any information sent over the internet, including personal data, carries some risk of interception and is not 100% secure. The Company cannot guarantee the security of any data transmitted online.

11. Hyperlinks to Third-Party Websites

On this website, you may encounter links to third-party applications and websites. Please note that these entities are not affiliates and are not under the company's control, and our privacy policy does not apply to them. They have 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 you visit its website before sharing any personal data. Confirm that their collection, use, and processing policies align with your preferences and priorities. Any data you choose to share should be provided directly to the service provider.

12. Policy Amendments

We reserve the right to update or modify our policy at any time. We will notify you of changes via our website and other appropriate channels. The updated privacy policy will be posted on the website, and the revised policy will take effect immediately upon publication unless stated otherwise.

13. Your Personal Data Rights

You retain full control and the final say over how your personal data is used, including verifying accuracy, correcting errors, and choosing to delete it or restrict both the scope and nature of how we process it.

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

Your personal data is protected in accordance with the rights described herein. By sending an email to the address below, you may immediately exercise those rights.

Accessing Your Rights

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

You may request your personal data for verification at any time, and it will be supplied in electronic format. If you request additional copies of your data being processed, beyond the initial copy supplied, a reasonable fee may be charged.

Rights granted by law and by the Privacy Policy must not infringe the rights of others. The company may deny or limit access to personal data if such access would compromise the rights and freedoms of other individuals.

Right to Rectify Errors

Any errors in your personal data, whether by omission or inaccurate information, may be corrected by you or by the Company to ensure it can be processed properly.

Erasure Rights

You have the right to request the 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 its removal and the Company has no legal obligation to retain it; 3) if you no longer consent to or accept any processing by us, even where lawful and based on our or a third-party provider's legitimate interests; and 4) if we are required by law to delete your data.

The right to erasure may be overridden by legal obligations under EU law or the laws of any member state. The same applies 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 the processing of your personal data be restricted 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 European Union or Member State law prevents deletion. 2) With your consent, when necessary to establish, exercise, or defend legal claims. 3) To protect the rights of another natural person.

Data Portability Rights

You have the right to access and review any personal data you have provided if you consented in any manner to its collection and the 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 technically feasible. This does not affect your right to have your data erased. This right may not be exercised if doing so would infringe the rights or freedoms of another natural person.

Right to object to data processing

Notwithstanding 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 right does not apply where there is a compelling legal basis to continue processing, including for the establishment, exercise, or defence of legal claims. In such circumstances, we may continue to process your personal data.

You may, at any time, object to the processing of your personal data for any direct marketing activities.

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 possible. This does not apply retroactively to any processing carried out before your withdrawal of consent.

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

If you believe your rights and freedoms have been violated in relation to 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 limited by European Union law or the laws of its Member States.

Once we receive your request concerning your personal data and its processing, we will provide access to the requested information, as outlined in Section 13 of this policy. We may extend this timeframe by up to two months, depending on the volume and nature of requests. If an extension is required, we will notify you within one month of receiving your request.

We will provide the requested information electronically at no cost, unless doing so would contravene applicable law or the provisions of Section 13. We may charge a reasonable fee or decline a request if it is deemed unfounded, excessive, or repetitive.

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