Privacy Policy

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

Spotlight Evocorex collects and retains data necessary for your trading activities. Details of how we collect and store this information are outlined in the following Privacy Policy.

Our policy is governed by the following principles:

• We are committed to full transparency about how we collect and store your personal information:

Our aim is to ensure you understand how we collect and process data so you can make informed decisions. We follow clear guidelines and processes for handling data on this website. Our policy outlines the specific methods we utilise, providing clear, concrete information about how it is used. You are in the driver's seat.

We’ll provide timely information whenever we determine you should be informed. Transparency is central to our approach.

Our trained team is always ready to answer any questions you may have about our processes, including our obligations under the laws of Australia. You can contact us at info@spotlight-evocorex.com

• We will not use personal information for any purpose other than as set out in our Privacy Policy.

We may process personal data for purposes necessary to operate Spotlight Evocorex services and to connect trader-members with third-party trading platforms. We may also process data to maintain and improve website functions and services, protect our rights, and comply with regulatory or other legal obligations. Finally, where this data is needed to perform administrative and other business functions related to the Services we provide to you, the client.

To deliver better services tailored to your preferences and needs, Spotlight Evocorex uses personal information.

• To access and effectively use the essential tools required to protect your personal data, both online and offline, and safeguard your rights:

At any time, you can contact us to access all of your personal information. We can also update or delete it as required. In addition, we can facilitate requests to transfer that information to you or an authorised third party. We offer this service and support to help you exercise your rights to privacy and control.

• Safeguard your personal information:

Our security systems use top-tier, bank-grade protections. While a 100% guarantee is not possible, we remain committed to continually enhancing our systems to the highest standards and strengthening the safeguards we already have in place.

We maintain a detailed and comprehensive privacy policy and industry-leading security systems.

1. The Scope?

This policy outlines our procedures and standards for the collection, processing, and sharing of any data relating to a natural person.

Our policy applies to all natural persons who are identifiable or already identified. This covers any individual who can be identified, or has been identified, through data entrusted to us or data we are able to access and/or combine.

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

We do not collect, or attempt to collect, any information about individuals under 18. We also do not permit anyone under 18 to utilise our platform for any purpose. If we discover a user or any data relating to someone under 18, we will delete that information immediately.

2. What personal information do we hold?

When you register with us, we collect the personal information needed to enable you to use our services. Where required, we may also ask you to provide personal information to verify ownership of an account, for example. To maintain and continually improve the quality of our services, we collect and analyse data about how you use our platform, as well as services offered by our third-party partners.

3. You are under no obligation to provide the company with your personal information.

While you are not obliged to provide your information to us, choosing not to do so may limit the services we can offer. It may also restrict your ability to use our platform.

4. What personal information do we collect? When you visit our website, we may collect the following personal information:

We do not collect information that personally identifies you. We do, however, record details such as your account activity, users’ IP addresses, and the date and time of access. For maintenance, security and support purposes, we retain system crash reports, browser details, and the type of device used to access your account. We also note the language associated with your account.

For the purposes of personal data collection, we only accept and retain the information you consent to provide to us when you connect with a third‑party trading platform through us.

The personal information you have supplied to third-party platforms may include details such as your full name, residential address, telephone number, and email address.

5. Why does the company need my personal information, and is it lawful for them to collect it?

The collection, storage and processing of your personal information by the company are undertaken solely for the purposes set out in this Policy. All of the above uses and processing comply with the relevant laws in Australia.

The company will not handle, process, or transmit your data except in accordance with the relevant laws in Australia. The following are the legal grounds for doing so:

• You have agreed to the company storing and processing 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 also 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 need to store and process your personal information.
• 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 relevant legal bases.

6. Disclosure of Personal Data to Third Parties

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

At your request, we may share certain personal data you provide with third-party services. In such cases, your data will be handled in accordance with those companies' privacy policies. This may include various digital trading platforms.

To better serve our clients and improve overall service quality, the company may share personal information with its affiliates and partner organisations.

Where required by law, or to protect the company’s 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 the sale of the company, seeking investment, or obtaining a loan—relevant data may be shared in a lawful and appropriate manner. This also covers any company merger, restructuring, consolidation, or bankruptcy, in accordance with the law.

7. Use of Cookies and Third-Party Services

For site analytics and in collaboration with advertising partners, this site may use cookies and similar technologies, in accordance with applicable laws and industry standards.

Cookies—small data files stored on your device when you visit a website—collect information about your browsing behaviour, preferences, and other usage data. They help personalise and enhance your experience by allowing us to remember your settings and tailor our services and communications accordingly. We also use cookies for website analytics and reporting, including compiling statistics that inform strategic planning.

There are, broadly speaking, two types of cookies used on this site. Session cookies are stored only for the duration of your session and are deleted when you close your browser. Persistent cookies remain stored in your browser even after you end a session. These allow the site to recognise you as a returning visitor and support your use of the site.

Types of cookies:

Cookies may be used as required, in line with their specific purpose:

Cookies are blocked or have been deleted

If you want to delete or block cookies, you will need to do so via your browser settings. Follow the links below for step-by-step instructions on how to do this in the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some functions and website features from working as intended.

ONLINE TRACKING NOTICE

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

Your personal data will be shared, at your request and discretion, with third-party trading platforms for a period of 12 months. Upon expiry of those 12 months, and with your consent, that data will be shared for a further 12 months.

Our operations include the routine review of all personal information to determine whether it is still required.

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

When required to deliver our services or for security reasons, personal data may be transferred to third countries (countries other than your own) and international organisations, with robust security protocols in place. We apply the highest practicable data security standards to protect your data and ensure you retain access to legal remedies and rights in all circumstances.

In the EEA (European Economic Area), all residents are protected by data protection laws and safeguards.

• Data transfers are carried out under EU legal jurisdiction and competence, in line with the standard data protection safeguards outlined 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 entities or authorities are conducted in accordance with Article 46(2). This is a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses, set out in Article 46(2)(c) of the GDPR, establish the conditions for data transfers and are applied accordingly. The Clauses can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For details about the security measures the company uses to safeguard your personal information during international data transfers, please send an email request to info@wealthwaydigital.uk

10. Protecting Personal Data

Personal data is safeguarded using the highest level of technical and organisational measures, in line with gold‑standard procedures. These measures are designed to prevent any unlawful or accidental destruction of data, as well as its loss or alteration.

While we apply the highest level of care and adopt gold-standard data protection practices, as required by law, it is not possible to guarantee in all circumstances that your personal data will remain error-free. Accordingly, we cannot be held liable for any disclosure of personal data, or for incidental, intangible, or consequential loss or damage. This includes circumstances beyond our control, such as disclosure arising from transmission errors, unauthorised third-party access, or other similar causes.

In response to legally binding requests from regulators or legal authorities, we may be required to disclose your personal information to those bodies. Once disclosed under a legal obligation, we cannot control how those authorities handle, store, or protect your information.

Any information transmitted over the internet, including personal information, carries a risk of interception and is not completely secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

On this website, you may encounter links to third‑party applications and websites. Please note these are independent and not affiliated with or controlled by our company, and our Privacy Policy does not apply to them. They have their own procedures and priorities for collecting and processing personal information, and we are not responsible for such activities. Use at your own discretion.

Always read the privacy policy of any company or service when visiting their website, before sharing any personal information. Ensure their data collection, use and processing policies align with your preferences and priorities. Any data 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 provide notice of changes on our website and through any 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 have full control and the final say over how your personal data is used, including the right to verify its accuracy, correct errors, and choose to delete it or restrict the scope and nature of our data processing.

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

Your personal information is protected under the rights described herein. By sending an email to the address below, you may exercise those rights immediately.

Accessing Your Rights

If the personal data you have provided to us is accurate, you may access that data at any time. Any of your personal data that we process is accessible to us and therefore can be verified.

You may request your personal data for verification at any time, and it will be supplied to you in electronic format. If you request additional copies of the data we process, beyond the initial copy provided, we may charge a reasonable fee.

Rights granted by law and our privacy policy must not infringe the rights of others. The company may refuse or restrict access to personal information if such access would infringe the rights and freedoms of others.

Right to Rectify Inaccuracies

You or the Company may correct any errors in your personal data, whether due to omissions or incorrect details, at any time to ensure it can be processed properly.

Erasure Rights

You have the right to request deletion of your personal data in the following circumstances: 1) if it has been processed without your consent or contrary to law; 2) when you ask us to remove it and the Company has no legal obligation to retain it; 3) if you object to our processing, even where lawful and within the Company’s or a third-party provider’s legitimate interests; and 4) where we are required by law to delete your data.

The right to deletion is overridden by legal obligations under EU or member state law. Likewise, it does not apply where data is required for the establishment, exercise or defence of legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal information where you believe it contains inaccuracies.

If you request that the use of your personal data be restricted, it will be deleted except in the following circumstances: 1) where the laws of the European Union or any Member State prevent deletion; 2) with your consent, where required to establish, exercise, or defend legal claims; 3) to protect the rights of another natural person.

Data Portability Rights

You have the right to access and review any personal data you have provided, where you have consented in any form to its collection and the processing is carried out by automated systems.

You have the right to request the transfer of your personal data to another company or organisation, where this is technically feasible. This does not affect your right to deletion or any other data rights. This right does not apply if exercising it would infringe the rights or freedoms of another individual.

Right to object to data processing

While the Company may rely on its legitimate interests—or those of a third‑party service provider—you have the right to object to the processing and request that it cease. This does not apply where there are compelling legal grounds to continue the processing, including to establish, exercise, or defend legal claims. In such circumstances, we may continue processing your personal data.

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

Right to Withdraw or Refuse Consent

You have the right to withdraw your consent to our processing of your personal data at any time, taking immediate effect where possible. This will not apply retroactively to any processing undertaken before you withdrew your consent.

If you are dissatisfied for any reason, you may lodge a complaint with a relevant 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, European Union Member States have designated regulatory and supervisory authorities for this purpose. 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 about your personal data and how it is processed, we will provide access to the information you have requested, as outlined in Section 13 of this policy. We may extend this timeframe by up to two months, depending on the volume and complexity of requests. If an extension is required, we will notify you within one month of receiving your request and confirm the revised deadline.

Requested information will be provided to you electronically at no charge, unless restricted by law or the provisions of Section 13. We reserve the right to charge a reasonable fee or decline requests that are frivolous, excessive, or repetitive.

We reserve the right to request additional proof of identity if there is any reasonable doubt about the person seeking access to personal data, for data protection and security purposes.