Privacy Policy

Your personal data and assets are our top priority. We are fully committed to safeguarding them.

As a trading platform, Primehill Toknix collects and stores data essential to your trading activity. Details of how we collect and store this data are set out in the Privacy Policy below.

The following principles underpin our policy:

• To ensure complete transparency about how we collect and store your personal data:

Our aim is to make it clear how we collect and process your data, so you can make informed decisions. We follow strict guidelines and procedures for handling information across this official website. This policy sets out the specific methods we use, providing clear and concrete details about how it works in practice. You remain in control.

We will always provide information promptly whenever we determine you should be informed. Transparency is central to how we operate.

Our specialist team is on hand to answer any questions you may have about our processes, including our obligations under United Kingdom law. You can contact us at: info@primehill-toknix.com

• We do 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: to ensure the proper operation of Primehill Toknix services and to facilitate connections between trader-members and third-party trading platforms. We also process data to maintain and enhance our official website functions and services, protect our rights, and comply with regulatory or other legal obligations. Finally, we process data where required to deliver administrative and other business functions related to the Services we provide to you, the client.

To provide better services tailored to your preferences and needs, Primehill Toknix processes personal data.

• To access the essential tools to protect your personal data and safeguard your rights:

You can contact us at any time to access the personal data we hold about you. We can update or delete it where appropriate. We also support requests to transfer your data to you or to a nominated third party. These services are in place to help you exercise your rights to privacy and control.

• Safeguard your personal data:

We employ industry-leading, bank‑grade security measures. While no system can be guaranteed 100% secure, we are committed to continuous improvement—regularly upgrading our defences and strengthening the safeguards we have in place.

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

1. The Scope?

This policy sets out our procedures for the collection, processing, and sharing of personal data relating to natural persons.

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

As defined in the Privacy Policy, the processing of data means the storage, management, and organisation of that personal data.

We neither collect nor seek to collect information about anyone under 18, and we do not permit individuals under 18 to use our platform for any purpose. If we become aware of a user or any data relating to someone under 18, we will delete that information immediately.

2. What personal data do we collect and store?

When you register on our official website, we collect the personal data required to enable you to use our services. Where necessary, we may also request additional information to verify ownership of your account. To maintain and improve service quality, we collect and analyse data on your use of our platform and those of our third-party partners.

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

While you are not obliged to provide us with your data, choosing not to may limit the services we can provide and could restrict your access to 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 could personally identify you. However, we record details such as your account activity, your IP address, and the date and time you access the service. For maintenance, security, and support, 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, we only collect and retain the information you explicitly consent to share with us when you use our service to connect with a third-party trading platform.

Personal data you have shared with 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 collect it?

The collection, storage, and processing of your personal information by the company are solely for the purposes set out in the Policy. All such activities are carried out in accordance with the applicable laws of United Kingdom.

The company will only handle, process, or transmit your data in accordance with the applicable laws of United Kingdom. The legal bases for this are as follows:

• By submitting your details to the company, you consent to the storage and processing of your personal data. You also authorise us to transfer this data to the relevant third-party trading platform, where appropriate. Your consent applies to the processing of your personal data for one or more specified purposes.
• To improve its services, establish or defend legal claims, and pursue legitimate interests, among other purposes, the company may be required to store and process your personal data.
• Data processing is 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 process your personal data, together with the corresponding legal bases.

6. Sharing of Personal Data with Third Parties

To enable the storage and processing of IP addresses, the conduct of user surveys and analytics, and other related services, the company may share anonymised personal data with third-party service providers acting on its behalf.

At your request, we may share certain personal data you provide with third-party services. In such cases, your information will be processed in accordance with that company’s privacy policy. This may include multiple trading platforms.

To enhance the services we provide to clients and improve overall service quality, the company may share personal information with its affiliates and 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.

In connection with significant corporate transactions, 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 may also occur in the event of a merger, restructuring, consolidation or insolvency, in accordance with applicable law.

7. Use of Cookies and Third-Party Services

In accordance with applicable law and industry standards, we may use cookies and similar technologies for website analytics and in collaboration with advertising partners.

Cookies are small files stored on your device when you visit a website. We use them to collect information about your browsing behaviour and preferences to personalise and enhance your experience. Cookies enable us to remember your settings and preferences, and to tailor our services accordingly. We also use cookies for website analytics and to compile statistics that support strategic planning.

Broadly, there are two types of cookies used on this website. Session cookies are stored in your browser only for the duration of your visit and are deleted when you close your browser. Persistent cookies remain in your browser after your session ends; they help the site recognise you when you return and make the site easier to use.

Types of cookies:

We may use cookies where necessary, in line with their intended purposes:

Cookies are blocked or have been deleted

To delete or block cookies, please use 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 may prevent certain functions and website 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 in this policy. It may be kept for longer where required by applicable laws, regulations, or our company policies.

At your request and discretion, we will share your personal data with third-party trading platforms for 12 months. Upon expiry of that period, and with your consent, we will continue sharing it for a further 12 months.

As part of our operations, we regularly review all personal data to determine whether it is still required.

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

Where necessary to deliver our services and/or for security purposes, we may transfer personal data to third countries (i.e. countries other than your own) and to international organisations, using robust, verified security protocols. We apply the highest standards of data protection to safeguard your information and ensure you retain access to legal remedies and rights in all circumstances.

All residents of the EEA (European Economic Area) are protected by data protection regulations and safeguards.

• All data transfers are carried out under the jurisdiction and competence of the EU, 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 bodies or authorities are conducted in accordance with Article 46(2). These transfers are subject to a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses (SCCs), issued under Article 46(2)(c) of the GDPR, set the conditions for international data transfers, and such transfers take place in accordance with them. The Clauses are available on the European Commission’s official website 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 of the specific security measures the company uses to protect your personal data during third-country transfers, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is protected using technical and organisational measures to the highest standards, in line with established best practice. These controls help prevent unlawful or accidental destruction, loss, or alteration of that data.

Although we apply the highest level of care and follow gold-standard data protection procedures as set out in law, we cannot guarantee that your personal data will be entirely error-free in all circumstances. Accordingly, we cannot be held liable for any disclosure of personal data, or for incidental, intangible or consequential loss or damage. This includes situations beyond our control, such as disclosure arising from transmission errors, unauthorised third-party access, or similar causes.

If we receive a legally binding request from regulators or legal authorities, we may be required to disclose your personal data to them. Once disclosed under 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 completely secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

On this website you may find links to third‑party applications and websites. These are not part of our official website, are neither affiliated with us nor under our control, and our privacy policy does not apply to them. They have their own policies and procedures for collecting and processing personal data, and we are not responsible for their practices. Please use your own discretion.

Before sharing any personal data, always review the privacy policy of the company or service on its official website. Check that their data collection, use and processing practices align with your preferences and priorities. If you choose to share information, do so directly with the service provider.

12. Policy Amendments

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

13. Your rights in relation to your personal data

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

This page contains information relevant to EEA residents:

Your personal data is protected under the rights described herein. You can exercise those rights immediately 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 it at any time. Any of your personal data that is being processed is accessible to us and therefore verifiable.

You may request a copy of your personal data at any time for verification purposes, and we will provide it in electronic form. If you require additional copies of the data we process about you, beyond the initial copy, a reasonable fee may apply.

Rights provided by law and under the privacy policy must not infringe the rights of others. The company reserves the right to refuse or restrict access to personal data where granting access would infringe the rights and freedoms of others.

Right to Rectify Errors

If any of your personal data contains errors, whether by omission or inaccuracy, you or the Company may correct it to ensure proper processing.

Erasure Rights

You have the right to request the deletion of your personal data in the following circumstances: 1) if your data has been processed without your consent or outside legal parameters; 2) if you ask us to erase your data and we have no legal reason to retain it; 3) if you object to any further processing by us, even where lawful and based on our or a third-party provider’s legitimate interests; and 4) if we are legally required to delete your data.

Your 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 required to establish, exercise or defend legal claims.

Right to Restrict Data Processing

You have the right to request that the processing of your personal information be restricted if you believe it is inaccurate.

If you request that the use of your personal data be restricted, we will delete it unless one of the following applies: 1) EU or Member State law prevents us from doing so; 2) with your consent, it is required to establish, exercise or defend 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 to its collection and it is processed by automated means.

You have the right to request the transfer 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. However, it cannot be exercised if doing so would infringe the rights or freedoms of another individual.

Right to challenge the processing of your personal data

While the Company may process data on the basis of its legitimate interests or those of a third-party service provider, you have the right to object and request that such processing cease. This right does not apply where there is a compelling legal reason to continue, including 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 direct marketing purposes.

Right to Withdraw or Refuse Consent

You may withdraw your consent to our processing of your personal data at any time and, where feasible, with immediate effect. This does not apply retroactively to any processing undertaken before your withdrawal.

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

If you believe your rights and freedoms have been violated in relation to the processing of your personal data, each EU Member State has a designated regulatory and supervisory authority. You may lodge a complaint with the relevant authority at your discretion.

Section 13 sets out the circumstances in which your personal data rights may be limited under 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 information you have requested, as set out 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 request. If an extension is necessary, we will notify you within one month of receiving your request and advise you of the revised deadline.

We will send the requested information to you electronically free of charge, unless doing so would contravene the law or the provisions of Section 13. We may charge a reasonable fee, or refuse to act on a request, if it is considered unfounded, excessive, or repetitive.

We reserve the right to request additional proof of identity if we have reasonable doubts about the individual making a personal data request, for data protection and security purposes.