Privacy Policy
Last update: 12.08.2026
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 website Lumen Capstead (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 Personal Data. That is why we created this page: to give you clear, relevant information through a range of methods and procedures.
If we determine that you need specific details, we will provide them at the appropriate time.
We are happy to answer your questions and provide clarifications within the limits set by law. Contact us by email at: info@lumencapstead.com
We will use Personal Data only for the purposes stated in this Policy.
We may 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 use meaningful tools that protect your rights regarding Personal Data:
We have dedicated resources in place to support the exercise of your rights. Contact us at any time to request information regarding your personal data. We can modify or delete it, or stop using it for specific or general purposes. We can also transfer the information to you or to a third party. We are equipped to accommodate your requests.
Protect Your Personal Data
While complete security of your Personal Data cannot be guaranteed, we will continue employing a variety of methods and techniques to help protect it.
Our Privacy and Security Policy is complete.
1. The Scope?
This Policy describes the types of Personal Data the Company collects on natural individuals, and how it processes, shares, and secures 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 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 18 years of age. We do not knowingly collect information from anyone under 18, and we do not knowingly permit such persons to use our services. If we learn that we have collected information from a child, we will delete it as quickly as possible.
2. What Personal Data Do We Collect?
We collect Personal Data when you access our Services and channels or visit our website. We may request Personal Data directly in certain instances. In others, we collect Personal Data by analysing how you use our Services or service channels, or by receiving your information from third-party partners.
You are not required to provide personal information to the company. However, choosing not to do so may prevent us from delivering our Services or granting you access to the website.
You are not obligated to provide Us with any Personal Data. In certain circumstances, however, withholding 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 does not constitute private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us at your own discretion when connecting with a third-party online trading platform through Us.
Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
The Company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use Personal Data concerning you. The Company relies on the following legal grounds to process Personal Data regarding you:
- You have provided consent for us to process your Personal Data for one or more purposes. 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 process personal data to meet a legitimate interest, such as improving Our Services or defending legal claims.
- Processing is required to comply with a legal obligation.
Contact us via email for further details regarding the processing necessary to safeguard these legitimate interests.
Below is a list of reasons and legal grounds for which we may use the personal data you provide us with.
Scope
Legal Basis
To share your personal data with third parties in order to give you access to digital trading
If you request this, we may collect personal data from you to forward to third-party companies.
You have provided consent for the processing of your Personal Data for one or more purposes.
2. 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 protect the Company's legitimate interests or the interests of a third party.
To comply with legal obligations, or with administrative, judicial, or regulatory requirements, Personal Data is processed as necessary to meet applicable legal requirements.
This processing is necessary to comply with legal obligations.
4. To Improve Our Services
We may use Personal Data to improve Our Services. This includes any crash or malfunction reports collected in connection with the Services.
Processing may also be necessary to protect the Company's legitimate interests or the interests of a third party.
To prevent fraud and misuse of Our Services
Processing may also be necessary to protect the Company's legitimate interests or the interests of a third party.
6. To Perform and Manage Actions in Line with the Requirements of Our Services
This includes back-office functions, business development activities, strategic decision-making, and oversight mechanisms.
Processing may be necessary to protect the Company's legitimate interests or the interests of a third party.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to make decisions on different issues.
Processing may be necessary to protect the legitimate interests of the Company or the interests 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 applicable laws, regulations, agreements, terms, and policies.
Processing may be necessary to pursue the Company's legitimate interests 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 services, and user experience analytics.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you have submitted to Us to those third-party trading platforms. Use of your Personal Data by these platforms is governed by their own 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 protect the rights of third parties or safeguard 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 company within the group, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
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 each time 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 products and services to your interests. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are temporarily downloaded to your device and expire shortly after 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 recognize you as a returning user and allow you to return to the website more easily.
Types of Cookies:
We may use them according to their intended purpose:
Cookie Type
Essential cookies
Scope
These cookies are essential for accessing the features you have requested and navigating our website. They are used to provide the information, products, and services you have asked us for.
Your device requires them to download and stream data. They allow you to navigate 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 you are logged in to the site. They are erased once you close your web browser (session Cookies).
Cookie Type
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and remember your preferences.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm you are logged in to the site. They are erased once you close your web browser (session cookies).
Cookie Type
Cookies for performance
Scope
Cookies collect statistical data on site performance and help us improve it. They also allow Us to conduct analysis of our website.
Additional Information
Cookies store anonymous data that cannot be linked to any identifiable or identified natural person. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you need to adjust your browser settings. Below are links to guide you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
If this occurs, some or all Website functions and features may not work as expected.
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 fulfill the purpose described in this Policy, or for longer periods where required or permitted by applicable law, regulations, policies, and orders.
We share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we hold to confirm it is still needed.
9. Transfers of personal information to a third country or to an international organisation
Your personal information may be transferred to other countries, meaning your personal data may be transmitted to a third country (a country other than the one in which you reside) or to international organizations or across jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and ensure that data users can assert their rights and access effective legal recourse.
These protections and safeguards are accessible to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation for which the EU Commission has determined an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out in compliance with standard data protection 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.
On request, we can provide details of the security measures we apply to safeguard your Personal Data when it is transferred to third-party countries or international organisations. Contact us at info@wealthwaydigital.uk
10. Security of Personal Data We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security. You are responsible for keeping your account credentials, including passwords and seed phrases, confidential. We will never ask for your seed phrase, and you should never share it with anyone. In the event of a data breach that affects your personal data, we will notify you and any applicable regulatory authorities in accordance with applicable law.
We take appropriate organizational and technical precautions to safeguard Personal Data. This includes preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will be maintained without error. We cannot be held accountable 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 legal obligations or other circumstances beyond our control require it, we may need to provide Personal Data concerning you to third parties, such as public authorities. We cannot control the security such third parties apply to your Personal Data in these situations.
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
The website contains links to third-party sites and applications. These applications and websites 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.
Before accessing or using any third-party website or app, We recommend that you review its privacy policy. We also advise caution when providing any Personal Data to them.
12. Modifications to this Policy
Before accessing or using any third-party website or app, We recommend that you review their privacy policies. We also recommend that you exercise discretion when providing them with any Personal Data.
13. Your Rights Regarding Your Personal Information
You are entitled to request that We verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete Personal Data no longer required by Us. You may also 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 exercise these rights by writing to the email address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. Where applicable, you are able to 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 upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfill it.
Right to rectification
The Company will 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 grounds apply: (a) Personal Data are no longer necessary for the purpose for which they were 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 of Personal Data based on legitimate interests pursued by Us or by a third party; (e) Personal Data have been unlawfully processed; or (f) 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 law or the law of a Member State, or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
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 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 rights under the right to erasure. The right to data portability does not infringe upon the rights or freedoms of others.
Right to object
You may object at any time to the use of Personal Data concerning you where processing is based on legitimate interests pursued by the Company or a third party, including profiling based solely on such legitimate interests. Where the Company demonstrates compelling legitimate grounds for the processing, We may continue processing unless you demonstrate that your rights, freedoms, and interests override those grounds, or unless processing is necessary for the exercise, establishment, or defense of legal claims.
With respect to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to Our processing of Personal Data concerning you at any time. This will not affect the lawfulness of any processing carried out based on your 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 with respect to the processing of Personal Data within the European Union.
The laws of the European Union and its Member States may limit your rights concerning Personal Data, as described in this section 13.
We will provide the information requested under the rights described in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the complexity and number of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
Subject to the provisions of section 13, information requested under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly if repetitive, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or may decline to act on the request.
Where We have reasonable doubts about the identity of the person submitting a request, the Company may request additional information to verify identity.