Privacy Policy

Last update: 30/9/22

We (referred to as “We”, “Us”, or “Our”) are dedicated to protecting your personal information and ensuring your privacy.

This Privacy Policy was crafted to enlighten you on the methods we use to gather and retain the data you submit via the website Lumena Zeph (the “website”).

These values shall be upheld: .

  • To be clear about how personal data related to you is gathered and managed:

Our goal is for you to make knowledgeable decisions about handling your personal data. That's why we've developed our platform. To achieve this, we utilize various strategies and systems to offer you pertinent insights into personal data usage.

Should we determine that you need particular specifics, we will offer the details to you at the right moment.

We are pleased to address any inquiries you might have and will clarify any restrictions mandated by law. You can reach us through email at the following address: info@ Lumena Zeph .com.

  • Private information will solely be utilized for the intentions outlined in the policy.

We may utilize your Personal Data for various reasons, including providing the website experience and linking you with external trading platforms (the 'Services'). Additionally, this information helps improve the site, safeguard our rights and interests, support service maintenance and delivery, comply with legal or regulatory requirements, and manage administrative and business tasks essential to delivering and facilitating your use of the services.

We also handle your personal data to gain a clearer insight into your preferences and requirements.

  • Utilize effective instruments to safeguard your entitlements concerning personal information:

We've allocated significant resources to ensure you can exercise your rights. Feel free to contact us at any time to inquire about your personal information. We can amend or erase it, cease using it for specific or general purposes. Transfer your details to you or a third party. We are prepared to fulfill your requests.

  • Protect your private information:

Although we cannot promise absolute safety for your personal information, we assure you that we will persist in utilizing diverse strategies and approaches to safeguard your personal data.

Our privacy and security guidelines are fully established.

1. The Scope?

This document outlines the kinds of personal information gathered on individuals by the company and details how it manages, shares with external entities, and secures this information, among other practices.

This Policy pertains to data connected to a recognized or recognizable individual. An identifiable person is someone who can be directly identified or is discernible through a mix of extra data that we possess or can access.

The Policy characterizes "processing" as any operation involving the collection or utilization of personal data. This includes the administration, organization, and safekeeping of such data.

Our offerings cater to a broad audience and are unsuitable for individuals under 18. We do not knowingly gather or request data from those younger than 18. Such individuals are not permitted to access our services. If we become aware of any data regarding minors, we will delete it promptly.

2. What information do we possess about you?

When you utilize our platform or explore our website, we gather your personal information. There are occasions when we might directly ask for your details. In other cases, we obtain your personal information by evaluating how you engage with our platform or through our communication channels, or by acquiring it from our third-party affiliates.

3. Providing personal details to the company is not mandatory, along with understanding the implications.

However, you are not required to share any personal information with us. In some situations, though, you might not need to provide such details. This may limit our ability to deliver services or prevent users from accessing the site.

4. What types of personal information might we collect? Upon accessing our site, we will gather the following details related to your identity.

This encompasses details about your internet activity record, data linked to your traffic (covering IP address, the date and time of access) the language employed, software error reports, the browser type, and specifics about the device you utilized. The data gathered does not include personal information and cannot be used to identify you.

Personal Information We collect from you: Any personal information you voluntarily share with Us when accessing a third-party online trading site through Us.

Personal details you offer directly to external platforms for trading purposes: this data includes your full name, residence, contact number, and email.

5. The grounds and justifications for handling personal information.

The company handles your personal information for reasons outlined in this section, following the legal frameworks pertinent to it.

Without a legitimate foundation, the company cannot utilize your personal information. The legal justifications that allow the company to handle your data are: .

  • You have agreed to the handling of your personal information for one or more purposes. This applies when you provide personal data through the site so we can pass them to a third-party trading platform.
  • The organization or an outside entity may need handling to fulfill their valid interest. For example, it's essential to enhance our offerings or to protect against legal disputes.
  • The process must comply with a legal requirement.

Reach out to us via email for further information about the procedures required to protect lawful interests.

Here is a compilation of the justifications and lawful bases for which we might utilize the data you supply to us. Personal information.

Scope
Legal basis

To share your details with external entities at your request for access to online trading platforms.

Should you request it, we might gather your personal information to pass it to companies in Singapore.

You have agreed to the handling of your personal information for one or several purposes.

To address your inquiries, feedback, or issues, personal information is essential to assist you in responding to any queries about the offerings.

The company's valid interests or the concerns of another party require processing.

To fulfill any statutory duty or regulatory, court, or legal demands, personal data is managed to satisfy legal mandates.

To fulfill legal duties, processing is essential.

To Improve Our Services, we may utilize Personal Data to advance Our offerings. This encompasses, among various aspects, any error reports or malfunctions we gather regarding the services.

The company's justified interests or those of a third party require processing.

Preventing Fraud and Abuse of Our Services

The legitimate interests of the company or the interests of a third party need to be processed.

To execute and oversee tasks that align with the criteria of our offerings, such endeavors encompass administrative duties, growth initiatives, strategic planning, supervisory frameworks, and more.

The company's valid needs or those of a third party require processing.

For decision-making on various matters, we utilize diverse analytical methods, such as evaluating statistical data, through different techniques, including statistical ones.

The rightful concerns of the organization or those of another party must be managed.

To Protect Our Assets, Rights and Interests Alongside Those of Others We Have Created HTML0 to Initiate and Defend Legal Claims Personal Data May Be Managed by Us to Guard Our Rights, Interests, and Assets, or Those Belonging to Other Parties, in Accordance with Any Related Laws, Regulations or Agreements, as Well as Any Terms, Conditions, or Policies.

The company’s rightful interests or those of a third party require processing.

6. Sharing Personal Information with External Parties.

The organization is able to share personal information with third-party firms that deliver services for us, such as hosting and storage providers for IP address data, as well as user experience analytics.

You have the option to request that we disclose your specific personal data to external trading platforms. In such cases, the personal information you provide will be shared with these third-party platforms. Their privacy policies will govern the handling of your personal data. Your information might be distributed among various trading platforms.

The organization might share personal information with affiliated groups or business associates. This collaboration supplies the company with the tools necessary to refine and enhance the offerings it provides to its clients.

Should the need arise to protect third-party interests or company assets, The Company is authorized to share personal information with regulatory bodies, local entities, or official authorities.

We might also choose to disclose your personal information to prospective investors or purchasers, or lenders associated with our organization or affiliated companies if such a transaction occurs (including any transfer or asset sale related to our company or other entities within the group) or as part of any merger, restructuring, consolidation, or bankruptcy involving our business or another entity within the group.

7. Third-party cookies and services.

External services, like those handling ads on our site or analytics firms, might be engaged. These entities may also employ cookies or alternative technologies.

Small text files called cookies are stored on your device each time you access or visit the site. These cookies collect data regarding your preferences and browsing behaviors to enhance your experience, manage your preferences, and tailor products and services you may like. Additionally, cookies are used for analytics and statistical purposes.

Some cookies we employ are session cookies, which are briefly stored on your device and disappear shortly once you exit your browser. Meanwhile, other cookies are persistent, meaning they linger on your device even after you’ve closed your browser. These persistent cookies help the website recognize returning visitors, facilitating a seamless experience when you revisit the site.

Types of cookies:

We might utilize them depending on their intended use.

The type of cookie

Cookies are essential and cannot be dispensed with.

Scope

These cookies are essential for accessing the options you’ve requested and for moving around our site. Cookies serve to deliver the data, items, and services you have inquired about.

They are essential for your device to acquire and stream data. This enables you to explore the site, access its functions, and revisit pages you've already viewed.

Additional Information

Cookies gather personal information, like your username and previous login date, to verify your active session on the site.

They disappear after you shut down your internet browser (session cookies).

The type of cookie

Capability cookies.

Scope

Each time you access our site, cookies help us identify you and remember your settings and choices.

Additional Information

Their validity extends to the expiry date, and they are retained even after closing the browser.

The type of cookie

Enhanced cookies for effectiveness.

Scope

Cookies collect statistical insights about the site's efficiency and assist in improving it. They also enable us to conduct website analysis.

Additional Information

Cookies hold anonymous information not linked to any specific or recognized natural individual.

You can remove them upon exiting your browser. Some cookies, however, remain valid indefinitely.

Cookies are obstructed or deleted.

To adjust or eliminate cookies, modify your browser's preferences. You’ll find links below to assist you with this in some of the most popular browsers.

  • firefox
  • Microsoft Edge
  • Google Chrome
  • safari

Nevertheless, keep in mind that some or all of the site's capabilities and elements may not operate as anticipated if this occurs.

ONLINE MONITORING NOTICE
This platform does not currently accommodate do-not-track requests.
8. The Storage of Your Personal Information.

The Company aims to keep your personal information as long as needed to achieve the objectives of data processing, as outlined in this policy, or for extended durations allowed by law, regulations, policies, and relevant directives.

Your details will be shared with third-party trading platforms for a year. Should you consent, we will extend this data sharing for an additional year.

We consistently evaluate the Personal Data we retain to confirm it is no longer necessary.

9. Sharing personal data with a foreign nation or an international entity.

Your personal details might be sent to other nations (e.g., your data may be relayed to another country besides Singapore or to global entities). Global Bodies or Regions. Our organization ensures comprehensive measures to safeguard your data and guarantees that individuals can exercise their rights and obtain effective legal remedies.

These protective measures and safeguards are available to every person residing in Singapore.

  • Transfer to a nation outside the EU or an international body which the European Commission recognizes as offering sufficient protection for personal data transferred there, consistent with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council dated 27 April 2016 (the “GDPR”).
  • The transfer occurs under a legally valid and enforceable contract between governmental bodies or agencies aligned with Singapore's Article 46 (2) (a).
  • The transfer complied with standard data protection clauses sanctioned by Singaporean authorities under Article 46 (2) (c) of the GDPR. The clauses approved by Singaporean regulators 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.

The firm is able to share details on the protective steps it takes to secure your personal information that is sent to third-party nations or international bodies. Reach out via email at info@wealthwaydigital.sg.

10. Protection of Personal Information. Ensuring the safety of individual data.

We have implemented suitable organizational and technical measures to protect personal data. This involves preventing the accidental or unlawful destruction, loss, or alteration of such data.

We cannot ensure or promise that your personal data's security will be perfectly preserved. We are also not liable for any non-physical, incidental, or consequential damages resulting from personal data exposure or use. This encompasses, but is not limited to, personal data disclosure caused by transmission errors, unauthorized third-party access, or other factors beyond our control.

Should we face any legal mandates or duties beyond our jurisdiction, we may need to disclose your personal information to external entities like government bodies. In these cases, we cannot assure the protection of your data by these third parties.

Transmitting personal information online cannot be guaranteed to be completely secure. The Company cannot guarantee the protection of the personal data you send to us via the Internet.

11. Links to external sites owned by third-party entities in Singapore.

The website includes links to external sites and apps. These platforms are not managed by the company. We do not assume responsibility for the collection or handling of personal information by these external entities. This Policy does not apply to activities conducted on these external sites or apps.

Before engaging with third-party sites or apps we suggest, please review their privacy policies before deciding to interact with their services. Additionally, we advise sharing your personal information with them.

12. Changes to this Policy.

This Policy may be revised at any moment. Should we revise this policy, we will inform you of the updates by placing the new version on our site. Furthermore, when major alterations are made, we will strive to notify you through methods we find suitable and will issue a notice on our site. Unless explicitly noted, any revisions will take effect once the updated policy is published.

13. Your entitlements pertaining to your personal data

You have the right to ask us to confirm the correctness of the personal data we collect about you, correct any errors, and remove all unnecessary personal data. Additionally, you can limit the types of personal information processing we perform.

For those living in Singapore, kindly visit this page: .

You can avail yourself of these entitlements regarding the details you submit concerning your personal data. To exercise your entitlements, please send an email to the address listed below.

Access rights

The firm can confirm the correctness of your personal information being handled. If accurate, you can access your data.

The organization aims to provide a digital version of the personal information currently under processing and may levy a modest charge for any extra copies. Should you request it, the data will be furnished in an electronic format.

The entitlement to view personal information should not oppose others' rights and freedoms. Should the request adversely affect another's privileges or liberties, the organization is entitled to deny the request or restrict its ability to satisfy it.

Entitlement to amendment.

The organization has the right to amend incorrect personal information. You have the right to request correction of incomplete personal data pertaining to you, considering the processing rationale.

Right to Erasure

The following grounds are relevant: (a) Personal data is no longer needed for the reason it was initially gathered or used; (b) You retract your consent and no legal ground exists for processing; (c) You dispute at any time, due to a specific situation, the handling of personal data about yourself based on legitimate interests carried out by us or third parties; (d) Data is processed illegally or (e) Data must be deleted to fulfill the legal duties of the corporation.

This entitlement is not relevant when processing is essential (a) to meet a mandate enforced by law that must be handled under Singaporean law or by laws of its states; or (b) to establish, pursue or protect legal claims.

Restrictions on processing

If you're worried about the precision of your personal data, you may request the company to restrict its processing.

Should you request the restriction of personal data, such data may be retained solely with your approval or to establish, enforce, or protect legal claims. This also applies to safeguarding another individual's rights or situations involving substantial public interest within Singapore or a member state.

Entitlement to transfer data

If an automated system performs the task and it's based on your consent or a contract you participate in, you possess the lawful right to access and review the personal data you provided to the company.

You have the right to request that your personal data be moved directly from the organization to another controller if it is technically possible. Exercising your right to data portability does not affect your rights under the right to deletion. The ability to transfer data does not infringe on the rights or freedoms of other individuals.

Right to challenge

You have the option to challenge any processing of your personal information that relies on legitimate interests of either the organization or another party at any moment. This includes profiling not exclusively grounded on those legitimate interests. Should we demonstrate that there are strong, legitimate reasons for processing your personal data, we may proceed, unless you can show that your rights, freedoms, or interests, or the assertion, establishment, or defense of legal claims outweigh these reasons.

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

Authority to decline permission.

You have the right to withdraw your approval for us to handle your personal information at any moment. This will not impact the legality and validity of any data processing done with your prior consent.

You have the right to file a grievance with the authority overseeing you.

You may file an appeal with an oversight body established by a member nation to protect individuals' basic rights concerning the handling of personal data in Singapore.

The regulations of Singapore and its laws might restrict your entitlements regarding personal data about you, as explained in this section 13.

We are committed to supplying you with the sought-after details in accordance with your entitlements outlined in section 13 of this contract. This will occur within a month from receiving your submission. Should circumstances require, such as the request's complexity or high volume, the duration may stretch to a maximum of two months. Within a month of receiving your application, we will inform you about any prolongation needed and provide the rationale.

Provided it does not conflict with the stipulations of section 13 of the statute, the data you seek under your entitlements in section 13 will be provided at no charge. However, if the request is found to be untenable or exorbitant, especially when repetitive, we might impose a reasonable fee to cover administrative costs for supplying the data or reporting the requested action. We may also choose not to respond.

If there are uncertainties about the true individual behind your request submission, the firm may seek additional details to verify the identity of the requester.