Kestrel Spartix

Privacy Policy

Last update: 10.08.2026

We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Kestrel Spartix website (the "Website").
We uphold the following principles:

To explain how we process and collect your personal information:

We want you to make informed choices about the use and processing of your Personal Data. This is why we created this page: to give you relevant information about how your Personal Data is used, through clear and consistent methods.
Where we believe you require specific details, we will provide these at the appropriate time.
We are happy to answer any questions and provide clarification, subject to any limitations imposed by law. You can reach us by email at: info@kestrelspartix.com

Personal Data will be used only for the purposes set out in this Policy.

We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities related to the Services.
We also process Personal Data to better understand your preferences and needs.

To exercise meaningful rights over your Personal Data

We maintain substantial resources to support the exercise of your rights. Contact Us at any time to request information regarding your personal data. We will modify or delete it, or stop using it for specific or general purposes. We can also transfer this information to you or to a third party. We will accommodate your requests wherever possible.

Protect Your Personal Data

While we cannot guarantee absolute security of your Personal Data, we will continue to employ a range of methods and techniques to help keep it protected.
This concludes our Privacy and Security Policy.

1. The Scope?

This Policy explains the types of Personal Data the Company collects from natural persons, how it processes and shares this data with third parties, how it secures such processing, and related matters.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, using additional information we hold or can access.
This Policy defines "processing" as any operation involving the use or collection of Personal Data, including its management, structuring, and storage.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from persons under 18 years old, and we do not knowingly permit such persons to use our services. If we become aware of any information collected from children, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

We collect Personal Data when you access our Services and channels or visit our website. We may request this information directly from you. In other cases, we collect Personal Data by analysing how you use our Services and service channels, or by receiving it from our third-party partners.

You are not required to disclose personal information to the company. However, doing so may prevent us from delivering our Services or granting you access to the website.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, failing to supply Personal Data may prevent Us from delivering the Services or prevent you from accessing the website.

4. What personal data do we collect? When you visit our website, we 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), language preference, software crash logs, browser type, and information regarding 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 a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Grounds for Processing 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 regarding you are:

  • You have given your consent to the processing of your Personal Data for one or more reasons, including where you submit personal information via the Website so that we may transfer it to a third-party trading platform.
  • The Company or a third party may process data to meet a legitimate interest, such as improving Our Services or defending legal claims.
  • Processing must be necessary to comply with a legal obligation.

Contact us by email for further details on the processing required to protect our legitimate interests.
Below is a list of reasons and legal grounds for which we may use the information you provide to us. Personal Data.

Scope

Legal Basis

Sharing your personal data with third parties at your request, to enable access to digital trading
If you request this, we may ask you for personal data to forward to third-party companies.

You have consented to the processing of your Personal Data for one or more reasons.

To respond to your requests, questions or concerns
Personal Data is necessary to help us address any questions you may have regarding the Services.

Processing may be necessary to pursue the Company's legitimate interests or those of a third party.

To comply with legal, administrative, judicial, or regulatory obligations, in which case Personal Data is processed to meet those requirements.

Processing is necessary to comply with our legal obligations.

4. To improve Our Services
We may use Personal Data to improve Our Services. This includes, among other things, any crash or malfunction reports collected in relation to the Services.

Processing may be necessary for the Company's legitimate interests or the interests of a third party.

To prevent fraud and misuse of Our Services

Processing is necessary for the legitimate interests of the Company or a third party.

To perform and manage actions in line with Our Services requirements
These activities include back-office functions, business development, strategic decision-making, and oversight mechanisms.

Processing may be necessary to pursue the Company's legitimate interests or those of a third party.

7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform decisions on different matters.

Processing may be necessary for the legitimate interests of the Company or of a third party.

8. To safeguard our assets, rights and interests, as well as those of third parties, and to establish and defend legal claims
We may process Personal Data to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations, agreements, terms or policies.

Processing is necessary for the legitimate interests of the Company or the interests of a third party.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and analysis of user experience.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you have given us to those third-party trading platforms. Use of your Personal Data is then subject to their respective 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 provides the Company with the resources needed to enhance and improve the products and services it offers customers.
Where necessary to safeguard the rights of third parties or protect assets, 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 within the group, in connection with a transaction such as the transfer or sale of assets belonging to the Company or any other group company, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.

7. Cookies and third-party services

We may use third-party services, such as advertising providers or analytics companies, on our website. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your preferences, and tailor the products and services you might enjoy. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are downloaded temporarily to your device and last only until you close your browser. Other cookies are persistent, remaining on your device for a period of time after you close your browser. Persistent cookies help the website recognise you as a returning user and allow you to return to the website more easily.

Types of Cookies:

We may use them for the following purposes:

Type of cookie

Essential cookies

Scope

These cookies are essential for accessing the features you have requested and for navigating our website. They provide the information, products and services you have asked us for.
Your device requires them to download and stream data, allowing you to navigate the website, use its features, and return to pages you have previously visited.

Additional Information

These Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).

Type of cookie

Functionality Cookies

Scope

Cookies allow us to recognise you each time you visit our site and to remember your preferences.

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 deleted once you close your web browser (session cookies).

Type of cookie

Cookies for performance

Scope

Cookies help us gather statistical data on the site's performance and support ongoing improvements. They also allow Us to carry out analysis of our website.

Additional Information

Cookies store anonymous data that cannot be linked to an identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.

Cookies blocked or removed
To block or remove cookies, you will need to change your browser settings. Below are links to guide you through the process for some of the most popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please note that some or all of the Website's 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 Your personal data

The Company will retain Personal Data for as long as necessary to fulfil the purpose for which it was processed, as described in this Policy, or for longer periods where required by law, regulations, policies, or applicable orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer needed before retaining it further.

9. Transfers of personal data to a third country or international organisation

Your personal data may be transferred to other countries, including third countries outside the one in which you reside, or to international organisations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can assert their rights and access effective legal recourse.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).

  • Transfer to a third country or international organisation which the EU Commission has determined provides adequate protection for Personal Data transferred to it, in accordance with 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 and enforceable agreement between public authorities or bodies under Article 46(2)(a).
  • The transfer was carried out in compliance with the standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These 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.

The Company can provide information on the security measures it applies to safeguard your Personal Data when transferred to third-party countries or international organisations. To request this information, email info@wealthwaydigital.uk

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures are reviewed and updated as needed to maintain an appropriate level of security. While we take reasonable steps to safeguard your personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security, and you provide your personal data at your own risk. You are responsible for keeping your account credentials, passwords, and seed phrase confidential. We will never ask for your seed phrase, and you should never share it with anyone. Any loss of your seed phrase or credentials due to your own actions falls outside our responsibility. Should a data breach occur that affects your personal data, we will notify you and any relevant authorities as required, and take appropriate steps to address the situation.

We have taken appropriate organisational and technical precautions to safeguard Personal Data, including measures to prevent its accidental or unlawful destruction, loss or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
Where required by legal or other obligations beyond our control, we may need to disclose Personal Data concerning you to third parties, such as public authorities. We cannot control the level of security such third parties apply to your Personal Data in these circumstances.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of Personal Data you transmit to Us online.

11. Hyperlinks to third-party websites

The website includes links to third-party sites and applications. These are not supervised by the Company, and We are not responsible for how such websites or apps collect or process Personal Data. This Policy does not apply to actions taken through third-party sites or apps.
Before accessing or using any third-party website or app, We recommend that you review its privacy policy. Any decision to provide Personal Data to third parties is at your own discretion.

12. Modifications to this Policy We may update this Policy from time to time. Any changes will take effect immediately upon posting to the website. Continued use of our Services after an update constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

Before accessing or using any third-party websites or apps We recommend, please review their privacy policies. We also advise caution when providing Personal Data to them.

13. Your rights with respect to your personal information

You are entitled to request that we verify the accuracy of Personal Data collected about you, to have any inaccuracies rectified, and to have Personal Data deleted where retention is no longer required. You may also request that we restrict the scope of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may request to exercise these rights by writing to the email address below.
Right of access
The Company can verify whether Personal Data concerning you is being processed. Where this is the case, you may access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Data will be provided electronically where requested.
The right of access must not adversely affect the rights and freedoms of others. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse the request or limit its response accordingly.
Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to request that incomplete Personal Data concerning you be completed, taking into account the purpose of processing.
Right to erasure
Erasure applies where: (a) Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, on grounds relating to your particular situation, to processing based on legitimate interests pursued by Us or a third party; (d) Personal Data has been unlawfully processed; or (e) Personal Data must be erased to comply with a legal obligation to which the Company is subject.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law, or (b) to establish, exercise, or defend legal claims.
Restriction of processing
If you contest the accuracy of your Personal Data, you may ask the Company to restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for reasons of important public interest within the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are party, you have the right to receive 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 the right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you where such processing is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those legitimate interests. Where the Company can demonstrate compelling legitimate grounds for processing, it may continue to do so unless you demonstrate that your rights, freedoms, and interests override those grounds, or that the processing is necessary for the establishment, exercise, or defense of legal claims.
Where Personal Data is processed for direct marketing purposes, you have the right to object at any time.
Right to withdraw consent
You may withdraw your consent to our processing of Personal Data about you at any time. This will not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State law may impose limitations on the rights described in this section 13.
We will provide the information requested under the rights set out in section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, taking into account the complexity and number of requests. We will notify you of any such extension, together with the reasons for it, within one month of receiving your request.
Subject to the provisions of this section 13, information requested under your rights in this section will be provided free of charge. Where a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover the administrative cost of providing the information or taking the requested action, or may decline to act on the request.
Where we have reasonable doubts as to the identity of the person making a request, the Company may request additional information to confirm identity.