Privacy Policy
Last update: 17.06.2026
We (also referred to as "We", "Us" or "Our") are committed to safeguarding your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the website Boreal Zinsmere (the "Website").
We uphold the following principles:
To be transparent about how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created this website. To support this, we use different methods and procedures to provide relevant information about how Personal Data is used.
If we believe you need specific details, we will provide them at the appropriate date and time.
We will answer any questions you may have and provide any clarifications you require, subject to any limitations imposed by law. You can reach us by email at: info@borealzinsmere.com
Personal Data will be used only for the purposes specified in the Policy.
Personal Data may be processed by Us for a range of purposes, including offering the website to you, connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities that support the delivery and use of the Services.
Personal Data are also processed by Us to better understand your preferences and needs.
To use important tools to safeguard your rights with respect to Personal Data:
We have substantial resources to support the exercise of your rights. Contact Us at any time to request Personal Data regarding your personal data. We will modify or delete it, stop using it for specific or general purposes, transfer the information to you or to an outside party, and accommodate your requests.
Protect your Personal Data:
Although we cannot guarantee the complete security of your Personal Data, we guarantee that we will continue to use a range of methods and techniques to ensure your Personal Data is protected.
Our Privacy and Security Policy is complete.
1. The Scope?
This policy describes the types of Personal Data Company collects from natural individuals and how it processes that data, shares it with third parties, secures it, and related matters.
This Policy applies to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through additional information we have or can access.
The Policy defines "processing" as a process that involves the use or collection of Personal Data. This includes the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person younger than 18 years old. We do not knowingly allow such persons to use our services. If we learn that we have collected information about children, we will erase it as quickly as we can.
2. What personal Data Do We Hold About You?
When you access the service and channels or visit our website, we collect Personal Data. In certain instances, we may request your Personal Data. In other cases, we collect your Personal Data by analyzing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. No requirement to disclose personal information to the company and related consequences.
However, you are not obliged to provide Us with any Personal Data. In certain circumstances, not supplying Personal Data may prevent Us from offering the Services or prevent users from accessing the website.
4. What types of Personal Data can We collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including IP address, date of access, and time of access), the language you used, software crash logs, browser type, and details about the device you used. This information is not private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide to Us when you connect with an online trading platform of a third party through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your complete name, address, phone number, and email address.
5. The Legal Basis and Reasons for the Processing of Personal Data
The Company processes your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use Personal Data concerning you. The legal grounds on which the Company may process Personal Data concerning you are:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information via the Website so we can transfer it to a third-party trading platform.
- The Company or a third-party may require processing to meet their legitimate interest. For example, processing may be necessary to improve Our Services or defend legal claims.
- Processing must comply with a legal obligation.
Contact Us by email for more details about the processing necessary to safeguard the legitimate interests.
Below is a list of reasons and legal grounds on which we may use the information you provide to us. Personal Data.
Scope
Legal Basis
1. To provide your personal information to third-party companies at your request to gain access to digital trading
If you request access, we may ask you for Personal Data and forward it to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is necessary to answer any questions you may have regarding the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. Personal Data is processed to meet any legal obligation or administrative, judicial, or legal requirement.
Processing is required to comply with legal obligations.
4. To enhance Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To perform and manage actions consistent with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use different analytical techniques, including statistical methods, to make decisions on various issues.
Processing is necessary for the legitimate interests of the Company or a third party.
8. To safeguard our assets, rights, and interests, as well as those of a third party, we have developed HTML0 to establish and defend legal claims
We may process Personal Data to safeguard our rights, interests, and assets, or those of a third party, in compliance with any applicable laws, regulations, agreements, conditions, terms, or policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
The Company may also share Personal Data with third-party companies that provide services to us, including providers of hosting, storage, IP address information, and user experience analysis.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will share the Personal Data you provide to Us with third-party trading platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This may give the Company the resources needed to enhance and improve the products and services it provides to customers.
Where necessary to safeguard the rights or assets of third parties, The Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company in the group of companies if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group ) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.
7. Third-party cookies and services
Third-party services, such as companies that provide advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.
Cookies are tiny text files placed on your device whenever you visit or access the website. Cookies are used to gather information about your preferences and browsing habits, improve the user experience, keep track of your preferences, and customize the products and services you might enjoy. Cookies are also used for statistics and analytics.
Certain cookies we may use are session cookies. They are temporarily downloaded to your device and last for a short period before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are used to help the Website identify you as a returning user and allow you to return to the website.
Types of Cookies:
We may use them based on their purpose:
The type of cookie
Cookies are strictly necessary
Scope
These cookies are necessary for you to access the features you have requested and navigate our website. Cookies are used to provide the information, products, and services you have requested.
They are required for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are erased when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and help save your preferences.
Additional Information
Cookies collect Personal Data, such as your username, and the date of your last login to confirm that you are logged in to the site. They are erased when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data about the site's performance and help improve it. They also allow Us to analyze our website.
Additional Information
Cookies store anonymous data that is not associated with any identifiable or identified natural person. Some cookies can be removed when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, change your browser settings. The links below explain the process for some of the most common browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please be aware that some or all Website functions and features may not work as expected if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of personal data about You
The Company will retain Personal Data about you for as long as necessary to fulfill the purpose of processing Personal Data, as described in this Policy, or for longer time periods as permitted by law, regulations, policies, and applicable orders.
We will share your information with third-party trading platforms for a period of 12 months. If you agree to this, we will continue to share your data for another 12 months.
We regularly review retained Personal Data to confirm whether it is still needed.
9. Transfers of personal information to a third country or an international organisation
Your personal information may be transferred to other countries. This means your personal data may be transmitted to a third-country (i.e. a country other than the one in which you reside), or to international organizations or jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users can assert their rights and access effective legal recourse.
These protections and safeguards are available to all EEA (European Economic Area) residents.
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate security for Personal Data transferred to it under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. (the "GDPR")
- The transfer is made pursuant to a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in compliance with common data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission 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.
The Company can provide information about the security measures it uses to safeguard your Personal Data when transferred to third-party countries or international organisations. Email info@wealthwaydigital.uk
10. Security of Personal Data
We have taken appropriate organizational and technical precautions to safeguard Personal Data, including measures to prevent accidental or illegal destruction, loss, or modification of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including, but not limited to, any disclosure of Personal Data due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
Due to legal obligations or other obligations beyond our control, we may be required to provide Personal Data concerning you to third parties, such as public authorities. We cannot control the security provided for your Personal Data by third parties in these situations.
Personal Data cannot be transferred over the web in a completely safe way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to third party websites
Links to third-party sites and applications are provided on the website. These websites and applications are not supervised by the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
Before accessing or using any third-party websites or apps, We recommend that you read their privacy policies. We also suggest that you provide any Personal Data to them.
12. Modifications to this Policy
When you visit any third-party websites or apps, We recommend reading their privacy policies before deciding whether to access or use their apps. We also suggest providing any Personal Data to them.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of Personal Data collected about you, rectify any mistakes, and delete all Personal Data not required by Us. You may also restrict the types of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by emailing the address below.
Access rights
The Company can verify whether Personal Data concerning you are being processed. If they are, you may access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request adversely affects another person’s rights or freedoms, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company may rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of processing.
Right to Erasure
The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of Personal Data concerning you based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to comply with the Company’s legal obligation.
This right does not apply where processing is necessary: (a) to fulfil a legal obligation requiring processing under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data.
If you request restriction of Personal Data, the Personal Data may be retained only with your consent, to establish, exercise, or defend legal rights, to protect the rights of another natural person, or for reasons of significant public interest in the European Union or a Member State.
Right to data portability
If processing is carried out by an automated system and is based on consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to transfer data must not interfere with the rights or freedoms of anyone else.
Right to challenge
You have the right to object at any time to the processing of Personal Data concerning you based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can establish compelling legitimate grounds for processing Personal Data, we may continue doing so only if those grounds outweigh your rights, freedoms, or interests, or relate to the establishment, exercise, or defence of legal rights.
With respect to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to refuse consent
You may revoke your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before its withdrawal.
You are entitled to lodge a complaint with the authority that supervises you.
You may lodge an appeal with a supervisory authority established by a Member State to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
We will provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if needed, depending on the nature and number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Unless contrary to section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If a request is unjustified or excessive, particularly if repeated, We may charge a reasonable amount to cover the administrative expenses of providing the information or communicating the requested action. We may also refuse to act.
If the Company has doubts about the identity of the person making the request, it may request additional information.