Privacy Policy

Protecting your personal data and assets is our top priority. We are fully committed to safeguarding them.

LunoVion collects and stores information necessary for your trading activities on our trading platform. Details on how this data is collected and stored are outlined in the Privacy Policy below.

The following principles guide our policy:

• To ensure complete transparency about how we collect and store your personal data:

Our goal 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 official website. Our policy explains the specific methods we use, providing clear, concrete information on its use. You are in control.

We’re committed to transparency and will provide timely updates whenever we determine you should be informed.

Our trained support team is always ready to answer any questions about our processes, including our obligations under the laws of Malaysia. Please contact us at: info@lunovion.com

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

We may process personal data for purposes that include the essential operation of LunoVion services and connecting trader-members with third-party trading platforms. We may also use this data to maintain and improve website features and services on our official website, protect our rights, and comply with regulatory or other legal obligations. Finally, we process data as needed to deliver administrative and other business functions related to the Services provided to you, the client.

To enhance and tailor our services to your preferences and needs, LunoVion uses personal data.

• To access and use the essential tools that protect your personal data and safeguard your rights:

You may contact us at any time to access your personal data. We can update or delete it upon request, and we can transfer your data to you or to a designated third party. We provide these services to help you exercise your rights to privacy and control.

• Keep your personal data secure:

We employ banking‑grade security across our systems. While no solution can provide a 100% guarantee, we continuously upgrade our protection and strengthen the controls in place to deliver the highest possible level of security.

Our official website adheres to a detailed and comprehensive privacy policy and employs industry-leading security systems.

1. The Scope?

This policy outlines how we collect, process, and share all personal data.

The terms of this policy apply to all natural persons who are identifiable or have been identified. This includes any individual who can be identified, or has already been identified, using data entrusted to us or data we are able to access and/or combine.

Data processing, as outlined in the Privacy Policy, specifically covers the storage, management, and organisation of personal data.

We do not collect, and do not seek to collect, any information about individuals under the age of 18. Individuals under 18 are not permitted to use our platform for any purpose. If we discover a user or any data relating to a person under 18, that information will be deleted immediately.

2. What personal data do we retain?

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

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

You are not obliged to provide your data to us; however, if you choose not to, it may restrict the services we can offer and may limit your access to our platform.

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

We do not collect any data that can personally identify you. However, we collect non-personal information such as your account activity, your IP address, and the date and time you access our services. For maintenance, security, and support, we retain system crash reports, browser details, and the type of device used to access your account. We also record your account’s language preference.

Regarding personal data, we only collect and store the information you explicitly consent to share when you connect with a third-party trading platform through us.

Personal data you share with third-party platforms may include your full name, 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 data solely for the purposes set out in this Policy. All such activities comply with the applicable laws of Malaysia.

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

• You consent to the company storing and processing your personal data. By submitting your personal data to the company, you authorise us to transfer it to the relevant third-party trading platform. Your consent covers the processing of your personal data for one or more purposes.
• To improve its services, establish or defend legal claims, and pursue other legitimate interests, the company may need to store and process your personal data.
• We process data to comply with legal obligations.

If you would like more information about the data processing the company is required to undertake, please contact us via email.

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

6. Disclosure of Personal Data to Third Parties

To facilitate the storage and processing of IP addresses, the conduct of user surveys and analytics, and other related services, the company may share anonymised personal data with third-party service providers.

At your request, we may share specific personal data you provide with third-party services. In such cases, the use of your data will be governed by those companies’ privacy policies. This may include multiple digital trading platforms.

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

Where required by law, or to protect the company’s rights and assets and those of third-party partners, we may disclose data to competent legal or regulatory authorities.

In connection with significant corporate transactions—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 covers mergers, restructurings, consolidations, or bankruptcy proceedings, in accordance with applicable law.

7. Cookies and Third-Party Services

On our official website, we may use cookies and similar technologies for site analytics and in collaboration with our advertising partners, in line with applicable laws and industry standards.

Cookies are small data files stored on your device when you visit our official website. We use them to gather information about your browsing behaviour and preferences to personalise and enhance your experience. Cookies help us remember your settings and tailor our services accordingly. We also use them for site analytics and to compile statistics for strategic planning and optimisation.

There are two main types of cookies used 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. These help the site recognise you when you return and make it easier to use the site.

Types of cookies:

Cookies may be used where necessary, in accordance with their intended purposes:

Cookies are blocked or have been deleted

If you wish to delete or block cookies, please do so through your browser settings. Refer to the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

Blocking cookies may prevent some site functions and features from working as intended.

ONLINE TRACKING NOTICE

We will retain your personal data for as long as necessary to perform the operations described in this policy. Where required, we may keep it longer to comply with local laws, regulations, and company policies.

Your personal data will be shared with third-party trading platforms, at your request and discretion, for 12 months. When that period ends, and with your consent, it will be shared for a further 12 months.

As part of our operations, we regularly review all personal data to determine whether it remains necessary.

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

When required to deliver our services and/or for security reasons, personal data may be transferred to third countries (countries other than your own) and to international organisations, applying full security protocols. We implement data protection measures at the highest possible level to safeguard your information and ensure you can exercise your legal rights and remedies in all cases.

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

• All data transfers are carried out under EU legal jurisdiction and competence and comply with the standard data protection protocols set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council, dated 27 April 2016 (“GDPR”).
• All data transfers between public entities or authorities are carried out in accordance with Article 46(2) and are governed by a legally binding and enforceable agreement.
• The European Commission’s Standard Contractual Clauses (SCCs), pursuant to Article 46(2)(c) of the GDPR, set the conditions for international data transfers, and such transfers are conducted in accordance with these Clauses. The Clauses are available 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 further information about the specific security measures the company uses 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 highest-level technical and organisational measures that follow industry gold‑standard practices. These measures help prevent unlawful or accidental destruction, loss, or alteration of the data.

Although we apply rigorous, industry-standard and legally compliant measures to protect your data, we cannot guarantee that your personal information 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 loss or damage. This includes situations beyond our control, such as transmission errors, unauthorised third-party access, or similar causes.

If we receive a lawful request from regulators or other competent authorities, we may be required to disclose your personal data. Once disclosed under legal obligation, we cannot control how those authorities handle, store, or protect your personal data.

Any information transmitted over the internet, including personal data, 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. These parties are independent of us, are not affiliates, and are not under our control, and our Privacy Policy does not apply to them. They have their own procedures and priorities for collecting and processing personal data, and we are not responsible for their practices. Please review their terms and privacy policies and use such links at your own discretion.

Always review the privacy policy of any company or service on its official website before sharing any personal data. Confirm that their data collection, use, and processing practices align with your preferences and priorities. Any data you choose to share should be provided directly to the service provider.

12. Policy Amendments

We may update or change this policy at any time. We will notify you of any changes via our official website and other appropriate channels. The updated version of the 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 retain full control and the final say over how your personal data is used, including the right to verify its accuracy, correct any errors, and choose to delete it or restrict the scope and nature of any processing by us.

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

Your personal data is protected by the rights described herein. You may exercise these rights immediately by emailing the address below.

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 that we process is accessible to us and can therefore be verified.

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

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

Right to Rectify Errors

Any errors in your personal data—whether due to omissions or inaccurate details—may be corrected by you or the Company to ensure proper processing.

Erasure Rights

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

Your right to deletion may be limited where we are required to retain data to comply with EU law or the laws of any EU Member State. It likewise does not apply if the data is needed to establish, exercise, or defend legal claims.

Right to Restrict Data Processing

You have the right to request that we restrict the processing of your personal data if you believe it contains inaccuracies.

When you request that the use of your personal data be restricted, we will delete it unless one of the following applies: 1) we are prevented from doing so by law in the European Union or any Member State; 2) with your consent, where retention is necessary to establish, exercise, or defend legal claims; 3) to protect the rights of another natural person.

Your Right to Data Portability

If you have consented to the collection and processing of your personal data by automated systems, you have the right to access and review any personal data you have provided.

You have the right to request that your personal data be transferred to another company or organisation, where technically feasible. This does not affect your right to have your data deleted. However, this right cannot be exercised if doing so would infringe upon the rights or freedoms of another individual.

Right to challenge the processing of your data

Even when the Company relies 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 stop. This right does not apply where there is an overriding legal need to continue processing, including to establish, exercise, or defend legal claims. In such cases, we may continue processing your personal data.

You may, at any time, object to the processing of your personal data for direct marketing purposes.

Your Right to Withdraw or Decline Consent

You may withdraw your consent to our processing of your personal data at any time and, where possible, with immediate effect. This will not affect any processing carried out before your consent was withdrawn.

If you are dissatisfied for any reason, you have the right to lodge a complaint with the relevant legal, regulatory, or other supervisory authority.

If you believe your rights and freedoms have been affected in connection with the processing of your personal data, each European Union (EU) Member State has a designated regulatory or supervisory authority to handle such matters. You may lodge a complaint with the relevant authority at your discretion.

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

The requested information will be provided to you electronically at no cost, unless doing so would contravene the law or the provisions of Section 13. We may charge a reasonable fee, or refuse a request, if it is manifestly unfounded, excessive, or repetitive.

We reserve the right to request additional proof of identity if we have reasonable doubts about the identity of the person making a personal data request, to ensure data protection and security.