Privacy Policy

Your personal data and assets are our highest priority. We are fully committed to protecting them.

Hoog Fundevo collects and stores data necessary for your trading activities. The methods used to collect and store this data are detailed in the Privacy Policy below.

Our policy is grounded in the following principles:

• With the aim of providing complete transparency about our practices for collecting and storing your personal data:

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

Should we determine that you need to be notified, we will provide information without delay. Transparency is fundamental to us.

Our trained staff are always available to answer any questions you may have about any aspect of our processes, including our obligations under Belgium law. You can contact us at info@hoog-fundevo.com

• We do not use personal data for any purposes other than those set out in our Privacy Policy.

We may process personal data for purposes that include ensuring the proper operation of Hoog Fundevo services and connecting trader-members with third-party trading platforms. We may also process data to maintain and enhance website features and services; protect our rights; and comply with regulatory and other legal obligations. Finally, where this data is necessary to deliver administrative and other business functions related to the Services provided to you, the client.

To provide better services tailored to your preferences and needs, Hoog Fundevo processes personal data.

• To access and use essential tools that effectively safeguard your personal data and uphold your rights in this regard:

You can contact us at any time to access all personal data we hold about you. We can also correct or delete it upon request. In addition, we can facilitate transferring your data to you or to a chosen third party. We provide these services to help you exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems meet the highest standards, comparable to banking‑grade protections. While no system can be guaranteed 100 percent secure, we are committed to continually upgrading our defenses to the highest feasible level and strengthening the safeguards we already have in place.

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

1. The Scope?

This policy sets out the procedures we follow for collecting, processing, and sharing personal data relating to natural persons.

Our policy applies to all identifiable natural persons. This includes any natural person who can be, or has been, identified through 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 anyone under 18 to use our platform for any purpose. If we discover a user or any information relating to someone 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 needed to enable your use of our services. Where required, we may also ask for personal data to verify account ownership, for example. To improve and maintain service quality, we collect and analyse data about your use of our platform and services offered by 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 may limit the services we can offer. It may also restrict your ability to use our platform.

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

We do not collect data that can directly identify you. However, we do record details such as your account activity, the IP address used, and the date and time of access. For maintenance, security, and support purposes, we retain system crash reports, browser information, and the type of device used to access your account. We also record the language associated with your account.

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

The personal data you have shared with third-party platforms may include the following: 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 collect it?

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

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

• You have agreed to allow the company to store and process your personal data. By submitting your information to the company, you authorise us to transfer it to the relevant third-party trading platform. You have given your consent for your personal data to be processed for one or more purposes.
• To improve services, establish or defend legal claims, and pursue legitimate interests, among other reasons, the company may need to store and process your personal data.
• We process data as necessary to comply with legal obligations.

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

Below is a list of the specific purposes for which we may use your personal data, along with the corresponding legal bases.

6. Disclosure of Personal Data to Third Parties

To store and process IP addresses, to conduct user surveys and analytics, and to provide other related services where necessary, the company may share anonymised personal data with trusted third-party service providers.

At your request, we will share certain personal data you provide with third-party services. In such cases, the use of your data will be governed by the privacy policies of the relevant company. This may include various digital trading platforms.

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

Where required by law, or to protect our rights and assets and those of our third‑party partners, we may disclose data to competent legal or regulatory authorities.

During critical business transactions, such as selling the company, seeking investment, or obtaining a 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 the law.

7. Cookies and Third-Party Service Providers

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

Cookies—small text files stored on your device when you visit a website—are used to collect information about your browsing behaviour, preferences, and similar usage data. 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 cookies for site analytics and to compile statistics for strategic planning.

Broadly speaking, the site uses two types of cookies. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. Persistent cookies, by contrast, remain in your browser even after your session ends. These cookies enable the site to recognise you as a returning visitor and improve the convenience and personalisation of your experience on the site.

Types of cookies:

Cookies may be used only as necessary and for their intended purpose:

Cookies are blocked or have been deleted

If you want to delete or block cookies, you’ll need to manage them through your browser settings. For detailed step-by-step instructions, follow the links below covering the most widely used browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent certain services and site features from working as expected.

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 longer to comply with applicable local laws, regulations, and company policies.

Your personal data will be shared—only at your request and discretion—with third-party trading platforms for 12 months. After that 12-month period, and with your consent, that data will be shared for an additional 12 months.

As part of our operations, we routinely review all personal data to determine whether it remains necessary.

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

When necessary to deliver our services and/or for security reasons, personal data may be transferred to third countries (countries outside your own) and to international organizations with robust security safeguards. We implement data protection measures to the highest possible standard to safeguard your information and ensure you retain access to legal remedies and rights in all circumstances.

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

• All data transfers take place under the EU’s legal jurisdiction and competence, in line 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 data transfers between public entities or authorities are conducted in accordance with Article 46(2). This constitutes a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses (SCCs), pursuant to Article 46(2)(c) GDPR, set the conditions for data transfers, which are conducted in compliance with them. 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 details on the specific security measures the company uses to protect your personal data during transfers to third countries, please send your request by email to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is safeguarded using the highest-level technical and organizational measures, aligned with industry-leading standards. These measures are designed to prevent the destruction of data due to unlawful or accidental events, as well as the loss or alteration of that information.

Although we apply the highest standards of care and data protection measures as required by law, it is not possible to guarantee in all circumstances that your personal data will remain error-free. Accordingly, we cannot be held liable where personal data is disclosed or suffers incidental, intangible, or consequential harm. This includes situations beyond our control, such as disclosure arising from transmission errors, unauthorised third-party access, or any similar cause.

If we receive a legally binding request from regulators or other legal authorities, we may be required to disclose your personal data to them. After disclosure in response to such a legal obligation, 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 is not 100% secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

On our website, you may encounter links to third-party applications and websites. Please note that these are not affiliated with, or controlled by, our company, 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 them at your own discretion.

Always read the privacy policy of any company or service when visiting their website before providing any personal data. Ensure their data collection, use, and processing practices align with your preferences and priorities. Any information you choose to share should be provided directly to the service provider.

12. Policy Amendments

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

13. Your data protection rights

You retain full control and the final decision over how your personal data is used, including verifying its accuracy, correcting errors, and choosing to delete or limit the scope and nature of any processing we perform.

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

Your personal data is protected by the rights described herein. By emailing the address below, you can exercise these rights immediately.

Accessing Your Rights

You may access your personal data at any time. Any of your personal data we process is available to you and can therefore be verified.

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

Rights granted by law and under the privacy policy must not infringe the rights of others. The company may refuse or limit access to personal data if providing access would infringe the rights and freedoms of others.

Right to Rectify Errors

Any errors in your personal data, whether due to omission or inaccurate details, may be corrected by you or by the Company to ensure it is processed correctly.

Erasure Rights

You have the right to request the deletion of your personal data in the following situations: 1) if your personal data has been processed without your consent or outside legal boundaries; 2) if you ask us to remove it and the Company has no legal obligation to retain it; 3) if you no longer accept any processing by us, even when 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 imposed by EU or Member State law. Likewise, it does not apply where data is required for the establishment, exercise, or defence of legal claims.

Right to Restrict Data Processing

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

When you request that the processing of your personal data be restricted, it will be deleted except in the following circumstances: 1) where EU or Member State law requires retention. 2) With your consent, if needed for the establishment, exercise, or defence of legal claims. 3) To protect the rights of another natural person.

Your Right to Data Portability

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

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 erasure of your data. This right cannot be exercised where doing so would infringe the rights or freedoms of another individual.

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 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 processing your personal data.

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

Right to Withdraw or Refuse Consent

You may withdraw your consent to our processing of your personal data at any time, with immediate effect where possible. This does not apply retroactively to processing performed 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 other supervisory authority.

If you believe that your rights and freedoms have been violated in relation to the processing of your personal data, European Union Member States have established regulatory and supervisory authorities to address such matters. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines circumstances in which your personal data rights may be limited by European Union law or by the laws of Member States.

Upon receiving 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 period by up to two months, depending on the volume and complexity of requests. If an extension is necessary, 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 the law or the provisions of Section 13. We may charge a reasonable fee or refuse requests that are manifestly unfounded, excessive, or repetitive.

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