Privacy Policy

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

Bitrevo Circle collects and retains data necessary for your trading activities. The methods used to collect and store this information are explained in the following Privacy Policy

Our policy is underpinned by the following principles:

• To ensure complete transparency about our processes for collecting and storing your personal data:

Our aim is to explain clearly how we collect and process your data, so you can make informed decisions. We follow clear guidelines and processes for handling data on this website. Our policy sets out the specific methods we use, giving you transparent, detailed information about how your data is used. You are in the driving seat.

We will provide updates promptly whenever we determine you need to be informed. Transparency is central to our approach.

Our trained team is always on hand to answer any questions you may have about any aspect of our processes, including our obligations under the laws of {country}. You can contact us at info@bitrevo-circle.com

• We do not permit any use of personal data beyond what is set out in our Privacy Policy.

We may process personal data for purposes including ensuring the proper operation of Bitrevo Circle services and facilitating connections between trader members and third-party trading platforms. We may also do so to maintain and improve website functionality and services; to protect our rights; and to comply with regulatory or other legal obligations. Finally, we process such data as 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, Bitrevo Circle uses personal data.

• To ensure you are able to effectively use essential tools to protect your personal data and uphold your rights in this regard:

You may contact us at any time to request access to all of your personal data. We can update or delete it as required. We can also fulfil requests to transfer that data to you or to a nominated third party. We provide these services to help you better exercise your rights to privacy and control.

• Safeguard your personal data:

We deploy security systems of the highest quality, with bank-grade safeguards. While no solution can offer a 100% guarantee, we remain committed to continually enhancing our systems to the highest standards and strengthening the protections 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 our procedures for the collection, processing and sharing of personal data relating to natural persons.

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

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

We do not collect, and do not seek to collect, any information about individuals under the age of 18. We also do not allow anyone under 18 to use our platform for any purpose. If we become aware of a user or any information relating to someone under 18, we will delete that information immediately.

2. What personal data do we hold?

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 the highest quality of our services, we collect and analyse data about your use of our platform and that of our third-party partners.

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

Although you are under no obligation to provide your data, choosing not to do so may limit the services we can provide. It may also restrict your ability to use 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 any data that could personally identify you. We do collect information such as your account activity, users' IP addresses, and the date and time of access. For maintenance, security, and support services, we retain system crash reports, browser information, and the type of device used to access your account. We also collect information about the language used by your account.

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

The personal data you have provided to third-party platforms may include: 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 use and processing complies with applicable laws in {country}.

The company will only handle, process, or transmit your data in accordance with the applicable laws in {country}. The following are the legal bases for doing so:

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

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

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

6. Disclosure of Personal Data to Third Parties

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

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

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

Where required by law, or to protect our 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, seeking investment, or securing a loan, we may share relevant data in a lawful and appropriate manner. This also applies in the case of any merger, restructuring, consolidation, or insolvency, as permitted by law.

7. Cookies and Third-Party Service Providers

For site analytics and in partnership with advertising partners, we may use cookies and similar technologies, in accordance with applicable law and industry standards.

Cookies – small files stored on your device when you visit a website – are used to collect information about your browsing behaviour and preferences. Their purpose is to personalise and enhance your user experience. They allow us to remember your settings and tailor our service offerings accordingly. We also use cookies for site analytics and statistical reporting to support strategic planning.

Broadly, there are two types of cookies used on this site. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. The others are persistent cookies, which remain saved in your browser even after your session ends. These enable the site to recognise you as a returning visitor and make it easier for you to use the site.

Types of cookies:

Cookies may be used as required, in line with their intended purposes:

Cookies are blocked or 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 site operations and features from working as intended.

ONLINE TRACKING NOTICE

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

At your request and discretion, your personal data will be shared with third-party trading platforms for a period of 12 months. Following the expiry of that 12-month period, and with your consent, your data will be shared for a further 12 months.

Our operations include the routine review of all personal data to determine whether it remains necessary.

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

When necessary to deliver our services and for security purposes, personal data may be transferred to third countries (countries other than your own) and to international organisations using comprehensive security protocols. We apply data security measures to the highest standards to safeguard your data and ensure you can exercise your legal rights and remedies in all cases.

Across the EEA (European Economic Area), all residents benefit from data protection laws and safeguards.

• Data transfers are always conducted under EU legal jurisdiction and competence, in line with the data protection rules 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). This constitutes a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, adopted under Article 46(2)(c) of the GDPR, set the conditions for data transfers and such transfers occur 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 more information on the company’s specific security measures 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 protected with the highest level of technical and organisational measures, following gold‑standard procedures. These measures help prevent the destruction, loss, or alteration of data resulting from unlawful or accidental events.

While we exercise the utmost care and follow industry‑leading procedures for data protection, as required by law, it is not possible to guarantee in every circumstance that your personal data will remain entirely error‑free. For that reason, we cannot be held liable for any instance in which personal data is disclosed, or for loss or damage of an incidental, intangible, or consequential nature. This includes circumstances beyond our control, such as disclosure arising from transmission errors, unauthorised access by third parties, or any other similar cause.

In response to legally binding requests or orders from regulators, courts or other public authorities, we may be required to disclose your personal data. Once disclosed in compliance with the law, 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 this website, you may find links to third-party applications and websites. Please note that these are not affiliates, are not under the company's control, and our privacy policy does not apply to them. They have their own policies and procedures for the collection and processing of personal data, and we are not responsible for those activities. Use at your own discretion.

Always read a company or service’s privacy policy when you visit their website before sharing any personal data. Ensure their data collection, use and processing policies 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 amend 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 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 confirming its accuracy, correcting errors, and choosing to delete it or restrict the scope and nature of our processing.

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

Your personal data is protected under the rights set out herein. By emailing the address below, you can immediately exercise those rights.

Accessing Your Rights

If the personal data you have provided is accurate, you may access it at any time. Any of your personal data 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 the data being processed beyond the initial copy, 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 restrict access to personal data where such access would infringe the rights and freedoms of others.

Right to Rectify Errors

You or the Company may correct any errors in your personal data, whether due to omissions or inaccuracies, to ensure it is processed correctly.

Erasure Rights

You have the right to request the deletion of your personal data in the following circumstances. 1) If your personal data has been processed without your consent or beyond lawful grounds. 2) If you ask for that data to be removed and the Company has no legal obligation to retain it. 3) If you no longer consent to or accept any processing by us, even where lawful and within our legitimate interests or those of a third-party provider; and 4) If we are required by law to erase your data.

The right to erasure may be overridden and superseded by legal obligations imposed by the EU or any member state’s laws. Likewise, this applies where data is required for the exercise of, or defence against, legal claims.

Right to Restrict Data Processing

You have the right to request that the processing of your personal data be restricted where you believe it contains inaccuracies.

Upon request to restrict the use of your personal data, it will be deleted except under the following circumstances: 1) where EU or Member State law prevents this. 2) With your consent, when needed to establish, exercise or defend legal claims. 3) To protect another natural person’s rights.

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 to processing performed by automated systems.

You have the right to request the transfer of any and all personal data to another company or organisation, where this is technically feasible. This does not affect your right to have your data deleted. This right cannot be exercised where doing so would infringe the rights or freedoms of another individual.

Right to contest data processing

Without prejudice to the Company’s right to pursue our 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 an overriding legal necessity to continue processing, including for the establishment, exercise or defence of legal claims. In such cases, we may continue to process your personal data.

You may at any time request that your personal data not be processed for any direct marketing purposes.

Right to Decline or Withdraw 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 retrospectively to processing carried out before your withdrawal of consent.

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, the Member States of the European Union have established regulatory and supervisory authorities to address such matters. You may lodge a complaint with these authorities at your discretion.

Section 13 outlines 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 relating to your personal data and its processing, we will provide you with access to the information you have requested, as outlined in Section 13 of this policy. We reserve the right to extend this timeframe by up to two months, depending on the overall volume of requests and the specific nature of your request. If an extension is required, we will notify you in writing of the new deadline within one month of receiving your request.

Requested information will be provided to you electronically at no cost, unless this would conflict with the law or the provisions of Section 13. We reserve the right to charge a reasonable fee or decline a request that is deemed unfounded, excessive or repetitive.

We reserve the right to request further proof of identity where there is reasonable doubt about the individual submitting a personal data request, to ensure data protection and security.