Privacy Policy
Last update: 22.04.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website Borneo Fundholm (the "Website").
These principles will be upheld:
To ensure transparency in how your personal information is collected and processed:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created our website. To do this, we use various methods and procedures to provide you with relevant information about the use of Personal Data.
If we believe you need specific details, we will provide them at the appropriate date and time.
We are happy to answer any questions you may have and provide any clarification you need regarding any limitations imposed by law. You can reach us by email at the address below: info@borneo-fundholm.com
Personal Data will be used only for the purposes specified in the Policy.
We may process Personal Data for a range of purposes, including providing you with the website and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, complying with regulatory or legal obligations, and carrying out administrative and business activities that facilitate the delivery and use of the Services.
Personal Data is also processed by us to better understand your preferences and needs.
To use important tools to protect your rights regarding Personal Data:
To support the exercise of your rights, we have dedicated substantial resources. Contact Us at any time to request Personal Data about your personal data. We will amend or delete it, stop using it for specific or general purposes, and transfer the information to you or to a third party. We will do our best to accommodate your requests.
Protect your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to use various methods and techniques to help protect your Personal Data.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects from natural persons and how it processes, shares with third parties, secures, and otherwise handles that data.
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 through a combination of additional information that we have or can access.
The Policy defines "processing" as any activity involving 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 use by anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old. We do not knowingly allow such persons to use our services. If we become aware of any information relating to children, we will delete it as quickly as we can if we learn of it.
2. What Personal Data Do We Hold About You?
When you access our services and channels, or visit our website, we collect Personal Data. In certain cases, we may ask for your Personal Data. In other cases, we collect your Personal Data by analysing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. There is no obligation to provide personal information to the company and accept the consequences.
However, you are not required to provide Us with any Personal Data. In some circumstances, however, you may choose not to provide Us with any Personal Data. This may prevent Us from providing 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, data relating to your traffic (including IP address, the date of access, the time of access, and the date of access), the language used, software crash logs, the type of browser used, as well as details about the device you used. The information collected 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 directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.
5. The legal basis and reasons for processing Personal Data
Your Personal Data is processed by the Company for the purposes described in this section, and in line with the applicable legal basis.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data:
- You have given consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to meet their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
- Processing must comply with a legal obligation.
Contact us by email for further details about the processing required to protect legitimate interests.
Below is a list of the reasons and legal bases for which we may use the information you provide to us. Personal Data.
Scope
Legal Basis
To provide your personal information to third parties at your request to gain access to digital trading
If you request this, we may ask you for Personal Data to share with 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 required to help address any questions you may have about the Services.
The legitimate interests of the Company or those of a third party need to be processed.
3. To comply with any legal, administrative, or judicial obligation, Personal Data is processed to meet legal requirements.
Processing is necessary to meet legal obligations.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash or malfunction reports that we collect in connection with the Services.
The Company's legitimate interests or those of a third party need to be processed.
5. To prevent fraud and misuse of Our Services
The Company's legitimate interests or the interests of a third party need to be processed.
6. To carry out and manage activities in line with the requirements of Our Services
Such activities include back-office functions, business development initiatives, strategic decision-making, oversight mechanisms, etc.
The Company’s legitimate interests or those of a third party need to be processed.
7. To conduct analysis, including statistical analysis
To make decisions on various matters, we use different analytical techniques (including statistical methods).
The Company's legitimate interests or those of a third party need to be processed.
8. To protect our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
Personal Data may be processed by us to protect our rights, interests and assets, or those of third parties, in accordance with any applicable laws, regulations or agreements and any conditions, terms or policies.
The Company’s legitimate interests or those of a third party need to be processed.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party service providers that support us, such as hosting and storage providers, IP address information services, and user experience analytics.
You may also request that we provide specific Personal Data relating to you to third-party trading platforms. In such cases, we will share the Personal Data you provide to Us with those third-party trading platforms. The use of your Personal Data will be subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners. This may provide the Company with the resources it needs to enhance and improve the products and services it offers to its customers.
If necessary to protect the rights of third parties or 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 or buyers, or with lenders to the Company or any other company in the group, if the same 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. Cookies and services by third parties
Third-party services, such as those providing advertisements on our website or analytics companies, may be utilized. These companies may also use cookies or other technology.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and customize the products and services you may 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 of time until 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 enable you to return to the website.
Types of Cookies:
They may be used by us according to their purpose:
The cookie type
Cookies are essential
Scope
These cookies are required to let you access the features you’ve requested and navigate our website. Cookies are used to deliver the information, products and services you have asked us for.
They are needed 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 deleted once you close your web browser (session Cookies).
The cookie type
Functionality Cookies
Scope
Cookies help us recognize you each time you visit our site and also save your settings and preferences.
Additional Information
Cookies collect Personal Data, such as your username and your last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
The cookie type
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow Us to analyse our website.
Additional Information
Cookies store anonymous data that is not linked to any identifiable or identified natural person. They can be deleted when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or have been removed
To enable or delete cookies, you need to change your browser settings. Below are links to guide you through the process for some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note 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. The retention of personal data about You
The Company will retain your Personal Data for as long as necessary to fulfill the purpose of processing it, as described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for another 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfer of personal information to a third-party country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country (i.e. a country other than the one in which you reside) or to international organizations. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data users are able to exercise their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that 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, enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with standard 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 may provide information about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk
10. Personal Data Security
We have taken appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
Where required by law or due to other circumstances beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In these situations, we cannot control the security applied to your Personal Data by those third parties.
Personal Data cannot be transferred over the web in a completely secure 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 available on the website. These websites and applications are not under the Company's supervision. 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.
When you visit any third-party website or app, We recommend that you read their privacy policies before deciding to access or use their apps. We also recommend that you provide any Personal Data to them.
12. Changes 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 that you provide any Personal Data to them.
13. Your rights regarding your personal information
You have the right to ask us to confirm whether Personal Data about you is being collected, to correct any errors, and to delete any Personal Data that is not required by Us. You may also request that we restrict certain types of processing of personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you in relation to the information you provide concerning your Personal Data. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company may verify whether Personal Data about you is being processed. If it is, 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 provided 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 the rights and freedoms of another person, the Company may refuse to comply with the request or may limit the extent to which it fulfills it.
Right to rectification
The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.
Right to Erasure
The following reasons apply: (a) Personal Data is no longer needed for the purpose for which it was collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, for reasons relating to your particular situation, to the processing of Personal Data about you based on legitimate interests pursued either by Us or by a third party; (e) Personal Data has been unlawfully processed or (f) Personal Data must be deleted to comply with a legal obligation of the company.
This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or Member State law; or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may ask the Company to limit the processing of your Personal Data.
If you request that Personal Data be restricted, it may only be stored unless you give consent or unless it is needed to establish, exercise or defend legal rights, to protect the rights of another natural person, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
If the processing is carried out by automated means and is based on consent or 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 have the right to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not affect the rights or freedoms of others.
Right to challenge
You have the right at any time to object to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing Personal Data, we may continue unless you show that your rights, freedoms, or interests override those grounds, or unless the processing is for the establishment, exercise or defense of legal rights.
Concerning 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 withdraw your consent for Us to process Personal Data about you at anytime. This will not affect the legality and lawfulness of any processing carried out based on your consent before it was withdrawn.
You have the right to lodge a complaint with the supervisory authority responsible for you.
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.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide the information you request under the rights set out in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months, if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Unless otherwise provided under section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unfounded or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also refuse to act.
If we have doubts about the identity of the person who submitted your request, the Company may ask for additional information.