Privacy Policy

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

As part of our trading platform services, Spark Xyvor collects and retains information necessary for your trading activities. Details on how we collect and store this data are outlined in the Privacy Policy below.

Our policy is founded on the following principles:

• To ensure complete transparency about our personal data collection and storage practices:

Our aim is to ensure you understand how we collect and process data so you can make informed decisions. We maintain clear guidelines and processes for handling data on this official website. Our policy explains the specific methods we use, giving you clear, practical information on its use. You stay in control.

We will always share relevant information promptly whenever we determine you should be notified. Transparency is at the heart of how we operate.

Our experienced team is ready to answer any questions you may have about our processes, including our obligations under the laws of Malaysia. You can contact us at: info@spark-xyvor.com

• We do not use personal data for any purposes other than those outlined in our Privacy Policy.

We may process personal data for purposes such as ensuring the proper operation of Spark Xyvor services and connecting trader-members with third-party trading platforms via our official website. We may also use this data to maintain and improve website features and services, protect our rights, and fulfil regulatory or other legal obligations. Additionally, where necessary, we process personal data to perform administrative and other business functions related to the Services we provide to you, the client.

To provide improved services tailored to your preferences and needs, Spark Xyvor processes personal data.

• To use essential tools that help protect your personal data and secure your rights:

At any time, you may contact us to request access to your personal data. We can also update or delete it where appropriate. In addition, we can facilitate requests to transfer your data to you or to a nominated third party. We provide these services to help you exercise your rights to privacy and control.

• Safeguard your personal data:

We employ bank‑grade security measures and maintain the highest standards. While no system can offer a 100% guarantee, we continuously enhance our protections, upgrading our infrastructure and strengthening the safeguards already in place.

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

1. The Scope?

This policy sets out our procedures for the collection, processing, and sharing of personal data relating to natural persons.

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

As defined in the Privacy Policy, data processing specifically covers the storage, management and organisation of personal data.

We do not collect, or attempt to collect, any information about individuals under 18. We also do not allow anyone under 18 to use our platform for any purpose. If we discover that a user is under 18, or that we hold information relating to a person under 18, we will delete it immediately.

2. What personal data do we collect and retain?

When you register on our official website, we collect the personal data necessary to enable you to use our services. Where required, we may also request additional information to verify ownership of your account. To maintain and improve service quality, we collect and analyse data about how you use our platform and, where applicable, the services of our third-party partners.

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

You are not obliged to share your data with us. However, if you choose not to, the services we can provide may be limited, and your access to our platform may be restricted.

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

We do not collect information that can identify you personally. We collect details such as your specific account activity, your IP address, and the date and time of access. For maintenance, security, and support, we retain system crash reports, browser information, and the type of device used to access your account. We also record the language settings associated with your account.

We collect and retain only the personal information you expressly consent to share with us when you use our services to connect with a third-party trading platform.

Personal data you may have shared with third-party platforms may include your full name, residential address, phone number, and email address.

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

The company collects, stores, and processes your personal information solely for the purposes described in this Policy. All such uses and processing comply with applicable laws in Malaysia.

The company will not handle, process, or transmit your data except in accordance with the applicable laws in Malaysia. The legal grounds for doing so are set out below:

• You agree that the company may store and process your personal data. By submitting your information to us, including via our official website, you authorise us to transfer it to the relevant third-party trading platform where appropriate. You have consented to the processing of your personal data for one or more purposes.
• To improve our services, establish or defend legal rights, and pursue other legitimate interests, the company may be required to store and process your personal data.
• Data processing is necessary to comply with legal requirements.

For more information about the data processing our company is required to perform, please contact us by email.

Below is a list of the specific purposes for which we may process your personal data, together with the legal basis for each.

6. Disclosure of Personal Data to Third Parties

For purposes including storing and processing IP addresses, carrying out user surveys and analytics, and performing other related services, the company may share anonymised personal data with third-party service providers.

At your request, we will share certain personal information you provide with third-party services. In such cases, the use of your data will be governed by that company's privacy policies. This may include multiple digital trading platforms.

To better serve our clients and enhance our services, the company may share personal data with its affiliates and partner companies.

Where required by law, or to safeguard the rights and assets of the company and our third-party partners, we may share data with relevant legal or regulatory authorities.

In connection with a significant corporate transaction—such as the sale of the company, seeking investment, or obtaining a loan—we may share relevant data in a lawful and appropriate manner. This also applies in the event of any merger, restructuring, consolidation, or bankruptcy, in accordance with applicable law.

7. Cookies and Third-Party Services

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

Cookies are small text files stored on your device when you visit a website. We use cookies to collect information about your browsing behaviour and preferences to help personalise and enhance your experience on our official website. They allow us to remember your settings and tailor our service offerings accordingly. We also use cookies for site analytics and to compile statistics that support strategic planning.

We use two main types of cookies on this site. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. Persistent cookies remain in your browser after your session ends, enabling the site to recognise you when you return and helping to make your experience smoother.

Types of cookies:

Cookies may be used where necessary and only for their intended purposes:

Cookies are blocked or have been deleted

To delete or block cookies, please do so via your browser settings. Follow the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies will prevent some services and features on this site from working as intended.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to fulfil the purposes described elsewhere in this policy. It may be kept for a longer period where required by local laws, regulations, or company policies.

At your request, we will share your personal data with third-party trading platforms for 12 months. When this 12-month period ends, we will continue sharing it for a further 12 months with your consent.

As part of our operations, we routinely review all personal data to determine whether it is still required.

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

As necessary to deliver our services and/or for security purposes, we may transfer personal data to third countries (countries other than your own) and to international organizations, applying comprehensive security protocols. We maintain the highest standards of data protection to safeguard your information and ensure that your legal rights and remedies remain available in all cases.

Across the EEA (European Economic Area), all residents benefit from data protection laws and safeguards.

• All data transfers are conducted under the EU’s legal jurisdiction and competence and comply with the standard data protection safeguards set out 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 bodies or authorities are conducted in compliance with Article 46(2). This constitutes a legally binding and enforceable agreement.
• Data transfers are carried out in accordance with the European Commission’s Standard Contractual Clauses pursuant to Article 46(2)(c) of the GDPR. You can review the Clauses on the European Commission’s official website 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 on the specific safeguards the company applies to protect your personal data during transfers to third countries, please email your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is safeguarded with the highest level of technical and organisational measures, aligned with industry best-practice procedures. These controls help prevent unlawful or accidental destruction, loss, or alteration of data.

While we exercise the highest level of care and follow gold-standard, legally mandated procedures for data protection, we cannot guarantee that your personal data will remain entirely error-free in all circumstances. Accordingly, we will not be liable for any disclosure of personal data or for incidental, intangible, or consequential harm. This includes situations beyond our control, such as transmission errors, unauthorised third-party access, or other similar causes.

If we receive a legally binding request under applicable law from regulators, courts, or other competent authorities, we may be required to disclose your personal data to them. Once disclosed pursuant to such legal obligations, we cannot control how those authorities handle, store, or protect your data.

Information sent over the internet, including personal data, may be intercepted and is not completely secure. The Company cannot guarantee the security of any data transmitted online.

11. Hyperlinks to third-party websites

Links on this website may direct you to third-party applications and websites outside our official website. These third parties are neither affiliated with nor controlled by the company, and our privacy policy does not apply to them. They maintain their own policies and practices for collecting and processing personal data, for which we assume no responsibility. Please review their terms and use such services at your own discretion.

Always review the privacy policy of any company or service when you visit their official website, before sharing any personal data. Ensure their data collection, use, and processing practices align with your preferences and priorities. Any information you choose to provide should be shared directly with the service provider.

12. Policy Amendments

We may update or modify this policy at any time. We will notify you of any changes via our official website and other appropriate channels. The revised privacy policy will be published on the website and will take effect immediately upon posting, 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 any mistakes, and choose to delete it or restrict the scope and nature of our processing.

This page provides information relevant to EEA residents:

Your personal data is protected under the rights set out herein. By emailing the address below, you can exercise these rights immediately.

Accessing Your Rights

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

You can request access to your personal data at any time for verification, and we will provide it in electronic format. If you need additional copies of the data we process beyond the initial copy, a reasonable fee may apply.

Rights granted under the law and our Privacy Policy must not infringe the rights of others. The company may refuse or restrict access to personal data if such access would compromise the rights or freedoms of other individuals.

Right to Rectify Errors

If your personal data contains any omissions or inaccuracies, you or the Company may correct it to ensure proper processing.

Erasure Rights

You have the right to request the deletion of your personal data in the following circumstances. 1) If your personal data has been processed without your consent or beyond what is permitted by law. 2) If you request its removal and the Company has no legal obligation to retain it. 3) If you object to any further processing by us, even where lawful and based on our legitimate interests or those of a third-party provider. 4) If we are required by law to delete your data.

Your right to deletion may be overridden by legal obligations under EU or any Member State law. The same applies where data is necessary for the establishment, exercise, or defence of legal claims.

Right to Restrict Data Processing

You have the right to request that the processing of your personal data be restricted if 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 law in the European Union or any Member State prevents deletion; 2) with your consent, where necessary 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, if you have consented in any manner to its collection and to processing by automated systems.

You have the right to request the transfer of any or all of your personal data to another company or organisation, where technically feasible. This does not affect your right to have your data erased. This right cannot be exercised if doing so would infringe the rights or freedoms of another individual.

Right to object to data processing

Even when the Company relies on our legitimate interests, or those of a third-party service provider, you have the right to object to the processing and request that it stop. However, this does not apply where there is an overriding legal need to continue processing, including for the establishment, exercise, or defence of legal claims. In such cases, we may continue processing your personal data.

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

Your Right to Decline or Withdraw Consent

You may withdraw your consent to our processing of your personal data at any time, with immediate effect where feasible. This does not apply retroactively to processing completed before you withdrew your consent.

If you are dissatisfied for any reason, you may lodge a complaint with any relevant legal, regulatory, or supervisory authority.

If you believe your rights and freedoms have been infringed in connection with the processing of your personal data, the Member States of the European Union 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.

Upon receiving your request concerning your personal data and its processing, we will provide access to the information you have requested, as outlined in Section 13 of this policy. We may extend this period by up to two months, depending on the number of requests we receive and the nature of your request. If an extension is required, we will notify you within one month of receiving your request.

We will provide the requested information electronically at no charge, unless restricted by law or by the provisions of Section 13. We may charge a reasonable fee, or refuse requests that are unfounded, excessive, or repetitive.

For data protection and security, we may request additional proof of identity if there is reasonable doubt about the identity of the individual requesting access to personal data.