Privacy Policy

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

Vrh Finspire collects and retains data essential to your trading activities. The methods we use to collect and store this data are detailed in the Privacy Policy below.

Our policy is founded on the following principles:

• With the aim of providing full 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 an informed decision. We follow clear guidelines and processes for handling data on this website. Our policy details the specific methods we use, so you have clear, concrete information about how it is used. You are in the driver's seat.

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

Our trained staff are always available to answer any questions you may have about our processes, including our obligations under the laws of Hrvatska. You can contact us at: info@vrh-finspire.com

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

We may process personal data for the following purposes: ensuring the proper operation of Vrh Finspire services and linking trader members with third-party trading platforms. We may also do so to maintain and improve website features and services; protect our rights; and comply with regulatory or other legal obligations. Finally, where this data is required 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, Vrh Finspire processes personal data.

• To effectively use essential tools to protect your personal data and safeguard your rights in this regard:

At any time, you may contact us to access all personal data we hold about you. We can update or delete it upon request. We also support requests to transfer your data to you or to a designated third party. We provide these services to help you fully exercise your rights to privacy and control.

• Safeguard your personal data:

Our security systems meet the highest standards, using bank‑grade protections. While a 100% guarantee isn’t possible, we continually enhance our systems and strengthen the safeguards we already have in place.

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

1. The Scope?

This policy outlines our procedures for the collection, processing, and sharing of any and all data relating to a natural person.

Our policy applies to all natural persons who are identifiable or have been identified. This includes anyone who can be identified, or has already 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 data relating to a person under 18, we will remove that information immediately.

2. Which personal data do we store?

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

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

While you are not obligated to share your data, choosing not to do so may limit the full range of services we are able to provide. It may also result in restrictions on 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 personally identify you. We do, however, record details such as your specific account activity, users’ 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 associated with 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, phone number, and email address.

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

The company's collection, storage, and processing of your personal information are solely for the purposes set out in this Policy. All such uses and processing comply with applicable laws in Hrvatska.

The company may handle, process, or transmit your data only in compliance with applicable laws in Hrvatska. The legal bases for doing so are:

• You have agreed to allow the company to store and process your personal data. By submitting your information to the company, you authorize us to transfer it to the relevant third-party trading platform. You have given your consent to the processing of your personal data for one or more purposes.
• To enhance 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 meet legal obligations.

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

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

6. Disclosure of Personal Data to Third Parties

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

At your request, we may share certain personal data you provide with third-party services. In such cases, your data will be handled in accordance with the applicable privacy policies of those companies. This may include multiple digital trading platforms.

To enhance the services we provide to our clients and improve overall quality, the company may share personal data with its affiliates and partner companies.

When required by law, or to protect the company’s rights and assets and those of our third-party partners, we may disclose data to relevant legal or regulatory authorities.

In the event of a significant business transaction, such as a company sale, pursuit of investment, or a loan, the relevant data may be shared in a lawful and appropriate manner. This also applies in the case of any merger, restructuring, consolidation, or bankruptcy, in accordance with applicable law.

7. Cookies and Third-Party Service Providers

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

Cookies—small text files stored on your device when you visit a website—are used to collect information about your browsing behavior, preferences, and more. Their purpose is to personalize and enhance your user experience, enabling us to remember your settings and tailor our services accordingly. These cookies are also used for site analytics and to gather 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 remain in your browser even after your session ends. These enable the site to recognise you as a returning visitor and facilitate your use of the site.

Types of cookies:

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

Cookies are blocked or have been deleted

If you want to delete or block cookies, you can do this through 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 will prevent some site operations and features from working as intended.

ONLINE TRACKING NOTICE

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

Your personal data will be shared—at your request and discretion—with third-party trading platforms for a period of 12 months. Upon the expiration of that 12‑month period, and with your consent, that data will be shared for a further 12 months.

Our operations include routinely reviewing all personal data to determine whether it is still required.

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

When necessary to provide our services and for security reasons, personal data may be transferred to third countries (outside your country) and international organizations under robust security safeguards. We implement industry-leading data protection measures to safeguard your data and ensure you retain access to legal remedies and rights in all circumstances.

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

• Data transfers are always conducted under the EU’s legal jurisdiction and competence, in accordance 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, issued under Article 46(2)(c) of the GDPR, set the conditions for data transfers, which are carried out in accordance with them. The Clauses are available 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 security measures the company uses to safeguard 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 using top-tier technical and organisational measures in line with industry best practices. These measures effectively guard against unlawful or accidental destruction, as well as the loss or alteration of data.

While we apply the highest level of care and industry-leading data protection practices required by law, it is not possible to guarantee in every circumstance that your personal data will remain entirely error-free. Accordingly, we cannot be held liable for any disclosure of personal data, or for damages of an incidental, intangible, or consequential nature. This includes events beyond our control, such as disclosures arising from transmission errors, unauthorized third-party access, or other similar causes.

If we receive a legally binding request from regulators or public authorities, we may be required to disclose your personal data to those authorities. Once disclosed under 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 site, you may find links to third-party apps and websites. Please note that these entities are not our affiliates and are not under the company’s control, and our Privacy Policy does not apply to them. They maintain their own processes and priorities for collecting and processing personal data, and we are not responsible for their practices. Use at your own discretion.

Always review the privacy policy of any company or service when you visit their website before sharing any personal data. Ensure that their data 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 this policy at any time. We will announce any changes on our website and through other appropriate channels. The updated privacy policy will be posted on the website and will take effect immediately upon publication, unless stated otherwise.

13. Your rights regarding personal data

You retain full control and the final say over how your personal data is used, including the right to verify its accuracy, correct errors, and choose to delete it or restrict both 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 under 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 that we process is accessible to you and therefore verifiable.

You may request your personal data for verification at any time, and it will be provided to you in electronic form. If you request additional copies of your data that is being processed, beyond the copy already provided, a reasonable fee may be charged.

Rights granted by law and under this Privacy Policy must not infringe the rights of others. The company may refuse or restrict access to personal data if doing so would compromise the rights and freedoms of others.

Right to Rectify Errors

Any errors in your personal data, whether due to omissions or inaccuracies, may be corrected by you or by the Company to ensure it can be 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 applicable legal bases. 2) If you request its removal and the Company has no legal obligation to retain that data. 3) If you no longer consent to any processing by us, even if lawful and based on our or a third-party provider’s legitimate interests, and, finally, 4) If we are legally required to delete your data.

The right to deletion is subject to legal obligations imposed by the EU or any member state’s law. It likewise does not apply when data is necessary 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 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 obligations under European Union or Member State law prevent deletion. 2) With your consent, where it is necessary for the establishment, exercise, or defense of 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 have consented in any form 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 deleted. This right cannot be exercised if 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 the processing and request that it be stopped. However, this right does not apply where there is a pressing legal need to continue processing, such as to establish, exercise, or defend 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 and, where possible, with immediate effect. This does not apply retroactively to processing conducted before your consent was withdrawn.

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 European Union Member State has 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 or Member State laws.

Upon receiving your request regarding your personal data and its processing, we will provide access to the information you requested, as described 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.

We will provide the requested information electronically at no charge, unless doing so would conflict with applicable law or the provisions of Section 13. We reserve the right to charge a reasonable fee or to decline requests that are unfounded, excessive or repetitive.

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