Privacy Policy
Last update: 25.03.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect, use, and store the information you provide through the website Penang Modalspire (the "Website").
We are guided by the following principles:
To ensure transparency about how your personal information is collected and processed:
We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we have created this website. To support this, we use various methods and processes to provide you with clear and relevant information on the use of Personal Data.
If we determine that you need more specific details, we will provide the relevant information at the appropriate time.
If you have any questions, we are happy to assist and will provide clarification on any limitations required by law. You may contact us by email at: info@penang-modalspire.com
Personal Data will only be used for the purposes set out in this Policy.
We may process Personal Data for various purposes, including providing you with access to the website, 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 applicable legal and regulatory requirements, and carrying out administrative and business operations necessary for the provision and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To use important tools that help protect your rights in relation to Personal Data:
To help you exercise your rights, we have dedicated resources in place. Contact Us at any time to request access to your Personal Data. We can correct or delete it, stop processing it for specific or general purposes, and transfer the information to you or to a third party. We will do our best to fulfil your request.
Protect Your Personal Data:
While we cannot guarantee absolute security for your Personal Data, we are committed to continuously applying a range of measures and safeguards to keep your Personal Data protected.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy explains the types of Personal Data the Company collects from individuals, how it is processed, when it may be shared with third parties, and the measures taken to keep it secure.
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 through additional information that we hold or can reasonably access.
In this Policy, "processing" refers to any activity involving the use or collection of Personal Data. This includes organising, structuring, storing, and otherwise handling Personal Data.
Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect information from, or permit the use of our services by, anyone below 18 years of age. If we become aware that we have collected information relating to a child, we will delete it as soon as reasonably possible.
2. What Personal Data Do We Hold About You?
When you use our services and channels, or visit our website, we collect Personal Data. In some situations, we may ask you to provide your Personal Data directly. In other cases, we collect your Personal Data by monitoring how our Services or service channels are used, or by receiving your information from our third-party partners.
3. You are not required to disclose your personal information to the company, and the consequences of not doing so will be stated.
However, you are not required to provide Us with any Personal Data. In some cases, if you choose not to do so, We may be unable to provide the Services, or users may not be able to access the website.
4. What Personal Data may we collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity logs, traffic data (including your IP address, date and time of access), your selected language, software crash reports, the browser you use, and details about the device you used. The information collected is not personal data and cannot be used to identify you.
Personal Data We receive from you: any personal data that you voluntarily 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 enable trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
Your Personal Data is processed by the Company for the purposes set out in this section and in line with the applicable legal basis.
If there is no valid legal basis, the Company cannot process your Personal Data. The legal grounds on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we can pass it on to a third-party trading platform.
- The Company or a third party may need to process your data where this is necessary to serve their legitimate interests. For example, this may be required to improve Our Services or to establish, exercise, or defend legal claims.
- Processing is necessary to comply with a legal obligation.
Please contact us by email if you would like more information about the processing required to protect legitimate interests.
Below is a list of the purposes and legal bases for which we may use the Personal Data you provide to us.
Scope
Legal Basis
1. To help you access digital trading services, we may share your personal information with third parties at your request
If you request this, we may collect Personal Data from you and pass it on to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
We require Personal Data to address any enquiries you may have about the Services.
Processing is necessary to serve the Company's legitimate interests or those of a third party.
3. To comply with any legal, administrative or judicial requirement, Personal Data is processed as necessary to fulfil applicable legal obligations.
Processing is necessary to meet legal requirements.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash reports or information on service malfunctions that we collect in connection with the Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required for Our Services
These include back-office operations, business development, strategic planning, oversight processes, and related functions.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To carry out analysis, including statistical analysis
We use a range of analytical methods, including statistical techniques, to support decision-making on various matters.
Processing is necessary to serve the Company's legitimate interests or those of a third party.
8. To protect our assets, rights and interests, as well as those of third parties, we may process Personal Data to establish, exercise or defend legal claims
We may process Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions or policies.
Processing is necessary to serve the Company's legitimate interests or those of a third party.
6. Disclosure of Personal Data to Third Parties
The Company may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, IP address processing services, and user experience analytics providers.
You may also request that we share certain Personal Data relating to you with third-party trading platforms. In such cases, we will provide the Personal Data you have supplied to us to those third-party trading platforms. Any use of your Personal Data by these platforms will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners where this is necessary to provide the resources required to improve and enhance the products and services offered to our customers.
Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory bodies, local authorities, or other official agencies.
We may also share your Personal Data with potential investors, purchasers, or lenders to the Company or to any other company within the corporate group in connection with the same transaction (including the transfer or sale of assets of the Company or any other group company), or as part of any merger, reorganisation, consolidation, or insolvency proceeding involving the Company or any other company within the group.
7. Cookies and third-party services
We may use third-party services, such as advertising providers on our website and analytics companies. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They help collect information about your preferences and browsing behaviour so we can improve your user experience, remember your settings, and tailor products and services that may be relevant to you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporarily stored on your device and remain active only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period of time after your browser is closed. They help the Website recognise you as a returning user and make it easier for you to revisit the website.
Types of Cookies:
We may use them in line with their intended purpose:
Cookie type
Cookies are essential for the site to function properly
Scope
These cookies are essential to let you access the features you’ve requested and move around our website. They help us deliver the information, products and services you’ve asked for.
They are also needed for your device to download and stream data. This allows you to browse the website, use its features, and return to pages you’ve visited before.
Additional Information
Cookies collect Personal Data, including your username and your last login date, to verify that you are logged in to the site. They are deleted when you close your web browser (session Cookies).
Cookie type
Functionality Cookies
Scope
Cookies help us recognise you whenever you return to our site and remember your preferences.
Additional Information
Cookies may collect Personal Data, such as your username and your most recent login date, to verify that you are signed in to the site. These are deleted once you close your web browser (session Cookies).
Cookie type
Cookies for performance
Scope
Cookies are used to collect statistical data on how the site performs and to support ongoing improvements. They also allow Us to analyse activity on our website.
Additional Information
Cookies store anonymous information that cannot be linked to any identified or identifiable individual. Some are deleted when you close your browser, while others remain valid for an indefinite period.
Cookies are blocked or have been deleted
To block or delete cookies, you’ll 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 even all, features and functions of the Website may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service currently does not respond to do-not-track signals.
8. Retention of your personal data
The Company will retain your Personal Data only for as long as needed to fulfil the purposes for which it is processed, as set out in this Policy, or for any longer period permitted under applicable laws, regulations, policies, or binding requirements.
We will share your information with third-party trading platforms for a period of 12 months. If you give your consent, we will continue sharing your data for a further 12 months.
We review the Personal Data we hold on a regular basis to ensure it is no longer retained than necessary.
9. Transfer of personal information to a third country or an international organisation
Your personal information may be transferred to other countries (that is, your personal data may be sent to a country other than the one where you live) or to international organisations. The Company takes all necessary measures to protect the Personal Data you provide and to ensure that data subjects are able to exercise their rights and have access to effective legal remedies.
These protections and safeguards are available to all individuals residing in the European Economic Area (EEA).
- Transfer to a third country or international organisation that the EU Commission has recognised as providing an adequate level of 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 carried out under a legally binding and enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses approved by the relevant authorities for cross-border data transfers. You can view these clauses 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 in place to protect your Personal Data when it is transferred to third countries or international organisations. Please email info@wealthwaydigital.uk for further details.
10. Protection of Personal Data
We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
While we take reasonable steps to secure your Personal Data, we cannot guarantee that its security will always be maintained without interruption or error. We are also not liable for any indirect, incidental, or consequential loss or damage arising from the use of, or disclosure of, Personal Data, including but not limited to disclosure caused by transmission errors, unauthorised access by third parties, or any other circumstances beyond our reasonable control.
Where required by law or due to circumstances beyond our control, we may need to disclose your Personal Data to third parties, including relevant authorities. In such cases, we are unable to control how those third parties protect your Personal Data.
No transmission of Personal Data over the internet can be guaranteed as completely secure. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Links to third-party websites
Links to third-party websites and applications may be available on this website. These websites and applications are not operated or controlled by the Company. We are not responsible for how such websites or applications collect or process Personal Data. This Policy does not apply to any actions taken on or through those websites or applications.
If you visit any third-party website or application, we recommend that you review its privacy policy before choosing to access or use it. We also advise you to consider carefully before sharing any Personal Data with them.
12. Updates to this Policy
When visiting any third-party website or app, we recommend reading their privacy policies before deciding whether to access or use their services. We also advise you to consider carefully before providing them with any Personal Data.
13. Your rights regarding your personal data
You have the right to ask us to confirm whether we hold Personal Data about you, to correct any inaccuracies, and to delete any Personal Data that is no longer required by us. You may also request that we limit certain types of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, you may contact us by email at the address below.
Access rights
The Company may confirm whether your Personal Data is being processed. If it is, you have the right to 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. Where requested, the information will be provided in electronic form.
The right to access Personal Data must not adversely affect the rights and freedoms of others. If fulfilling a request would negatively affect another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can comply.
Right to rectification
The Company may correct inaccurate Personal Data. You are entitled to request that incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right to Erasure
This right applies in the following circumstances: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of your Personal Data where such processing is based on legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased to comply with a legal obligation applicable to the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation; or (b) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing has been restricted, the Personal Data may only be stored unless you give consent for further processing, or where processing is necessary for the establishment, exercise, or defence of legal claims, for the protection of the rights of another individual, or for reasons of substantial public interest under applicable law.
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 a party, you have the right to receive the Personal Data you have provided to the Company.
You are also entitled to request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights and freedoms of others.
Right to challenge
You have the right at any time to object to the processing of Personal Data concerning you where such processing is based on the legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. If we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue the processing.
In relation to direct marketing, you have the right at any time to object to the processing of your Personal Data.
Right to refuse consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out based on your consent before it was withdrawn.
You are entitled to lodge a complaint with the relevant supervisory authority.
You may submit a complaint to a supervisory authority responsible for protecting individuals’ rights in relation to the processing of Personal Data.
Applicable laws may limit your rights in relation to your Personal Data, 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 additional months where necessary, taking into account the complexity and number of requests. If an extension applies, we will inform you within one month of receiving your request and explain the reasons for the delay.
Unless otherwise permitted under section 13 or applicable law, the information you request under your rights in section 13 will be provided free of charge. However, if a request is unfounded or excessive, in particular because it is repetitive, 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 on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information to verify the request.