Gizlilik Politikası
Son güncelleme: 25.06.2026
We (also 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 Zümrüt Varlıkay website ("Website").
We uphold the following principles:
To be transparent about how we collect and process your personal data:
We want you to be in a position to make informed choices about how your Personal Data is used and processed. That is why we built our website. To support this, we use a range of methods and procedures to give you relevant information about how Personal Data is used.
Where we believe you need specific details, we will provide them at a suitable date and time.
We are glad to answer any questions you may have and, within the limits set by law, to give you any explanations you need. You can reach us by email at the following address: info@zumrutvarlikay.com
Personal Data will be used only for the purposes set out in the Policy.
We may process Personal Data for several purposes: to provide the website and connect you with third-party trading platforms ("Services"), to improve the site, to protect our rights and interests, to support the maintenance and provision of the Services, to meet any regulatory or legal obligations, and to carry out administrative and commercial activities that support the delivery and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To access important tools for protecting your rights regarding your personal data:
We provide the resources you need to exercise your rights. To make a request regarding your personal data, you can Contact Us at any time. We will amend or delete this data, or stop using it for specific or general purposes. We will transfer the information to you or to a third party. We can fulfill your requests.
Keep Your Personal Data Secure:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to use a range of methods and techniques to protect it.
Our Privacy and Security Policy is comprehensive.
1. Kapsam Nedir?
This policy explains the types of Personal Data the Company collects about natural persons, how we process that data, how we share it with third parties, how we secure our operations, and related matters.
This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or by combining additional information we hold or can access.
Under this Policy, "processing" means any operation that involves the use or collection of Personal Data, including managing, organizing, and storing it.
Our Services are designed for a general audience and are not intended for anyone under the age of 18. We do not knowingly request or collect information from anyone under 18, nor do we knowingly permit such persons to use our Services. If we learn that we hold any information relating to children, we will delete it as soon as possible.
2. Hangi Kişisel Verilerinizi Saklıyoruz?
We collect your Personal Data when you access the Services and channels or visit our website. In certain cases, we may request your Personal Data directly. In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving your information from our third-party partners.
3. No obligation to disclose personal data to the Company, and the consequences of withholding it.
You are not required to provide us with any Personal Data. However, in certain cases, declining to do so may prevent us from delivering our Services or granting you access to the website.
4. What types of Personal Data do we collect? When you visit our website, we collect the following personal information:
This includes information from your online activity log, traffic data (the IP address you connect from, the access date, and the access time), the language you use, software crash logs, the type of browser used, and details about your device. The information collected is not private in nature and cannot be used to identify you.
Personal Data We Receive From You: any personal data you choose to provide to Us when you connect to a third party's online trading platform through Us.
Personal information you provide specifically to third party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.
5. Legal Basis and Grounds for Processing Personal Data
Your Personal Data is processed by the company for the purposes described in this section and in accordance with the applicable legal basis.
The Company may not use your Personal Data without a legal basis. The legal bases 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 your personal information through the Website so that we can transfer your data to a third-party trading platform.
- The Company or a third party may carry out processing to pursue legitimate interests. For example, this is necessary to improve our Services or to defend against legal claims.
- Processing is necessary to comply with a legal obligation.
For more details about the processing necessary to protect legitimate interests, contact us by email.
Below is a list of the reasons and legal bases for using the information you provide to us. Personal Data.
Kapsam
Yasal Dayanak
1. Sharing your personal data with third parties at your request to enable access to digital trading
If you request it, we may ask you for Personal Data to pass on to third-party companies.
You consented to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions, or concerns
Personal Data is necessary to help us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the company or those of a third party.
3. Personal Data is processed to meet any legal obligation or administrative, judicial, legal, or regulatory requirement.
Processing is necessary to comply with legal obligations.
4. To improve our Services
We may use Personal Data to improve our Services. This includes, among other things, the crash or error reports we collect in connection with the Services.
Processing is necessary for the purposes of the legitimate interests of the company or a third party.
5. To prevent fraud and abuse of our Services
Processing is necessary for the legitimate interests of the company or those of a third party.
6. Carry out and manage operations consistent with the requirements of our Services
Such activities cover back-office functions, business development, strategic decision-making, audit mechanisms, and similar processes.
Processing is necessary for the purposes of the legitimate interests of the company or a third party.
7. To perform analyses such as statistical analysis
We use various analytical techniques, including statistical ones, to support decision-making across different areas.
Processing is necessary for the legitimate interests of the Company or those of a third party.
8. To establish and defend legal claims that protect our assets, rights, and interests, as well as the rights of third parties
We may process Personal Data to protect our rights, interests, and assets, or the rights of third parties, in accordance with all applicable laws, regulations, or contracts and any related terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. Sharing Personal Data with Third Parties
The Company may share Personal Data, including IP address information, along with user experience analytics, with third-party service providers such as hosting and storage providers.
You may also request that we provide certain Personal Data about you to third-party trading platforms. In such cases, we will transfer the Personal Data you provide to those platforms. The use of your Personal Data will then be governed by the privacy policies of those platforms. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners. This gives the Company access to the resources needed to develop and improve the products and services offered to its customers.
Where necessary to protect the rights or property of third parties, the Company may share Personal Data with regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in connection with a relevant transaction (including the transfer or sale of assets belonging to the Company or any other company in the group) or as part of a merger, restructuring, consolidation, or insolvency of the Company or any other business within the group.
7. Third-party cookies and services
Our website may use third-party services such as advertising providers or analytics companies. These companies may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, track your settings, and tailor the products and services that may interest you. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are downloaded temporarily to your device and remain only for a short time, until you close your browser. Others are persistent cookies. Persistent cookies stay on your device for a period after you close your browser. They help the website recognize you as a returning user and encourage users to come back.
Çerez Türleri:
They can be used by us according to their purposes:
Çerez türü
Çerezler kesinlikle gereklidir
Kapsam
These cookies are necessary for you to access the features you request and navigate our website. They are used to provide the information, products, and services you ask of us.
They enable your device to download data and stream content, allowing you to browse the website, use its features, and return to pages you have previously visited.
Ek Bilgiler
Cookies collect Personal Data such as your username to verify that you are logged in to the site, along with the date of your last login. These cookies are deleted when you close your web browser (session cookies).
Çerez türü
İşlevsellik Çerezleri
Kapsam
Çerezler, sitemizi her ziyaret edişinizde sizi tanımamızı ve tercihlerinizi hatırlamamızı sağlar.
Ek Bilgiler
Cookies collect Personal Data such as your username to confirm that you are logged in, along with the date of your last login. They are deleted when you close your web browser (session Cookies).
Çerez türü
Performans çerezleri
Kapsam
Cookies are used to gather statistical data on the site's performance and help us improve it. They also allow us to analyze how our website is used.
Ek Bilgiler
Cookies store anonymous data that cannot be linked to an identified or identifiable individual. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies blocked or removed
To block or remove cookies, you need to change your browser settings. Below are links to help you do this in some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that if you do so, certain functions or all of the Website's functions and features may not work as you expect.
ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. Retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfil the Personal Data processing purposes described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we retain to confirm it is no longer required.
9. Transfer of personal data to a third country or international organisation
Your personal data may be transferred to other countries, meaning it may be sent to a third country (a country other than the one you reside in) or to international organizations or jurisdictions. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data subjects can exercise their rights and access effective legal remedies.
These protections and safeguards are available to everyone residing in the EEA (European Economic Area).
- Transfers to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for the Personal Data being transferred, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("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 the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission 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.
The Company can provide information about the security measures it applies to protect your Personal Data transferred to third countries or international organisations. Send an email to: info@wealthwaydigital.uk
10. Kişisel Verilerin Güvenliği
We have implemented appropriate organizational and technical measures to protect Personal Data. These include safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without fault. Nor can we be held liable for any non-material, incidental, or indirect damages arising from the use or disclosure of Personal Data. This includes, without limitation, Personal Data disclosed as a result of transmission errors, unauthorized access by a third party, or any other cause beyond our control.
In the case of legal obligations or other obligations beyond our control, we may be required to provide Personal Data relating to you to third parties such as public authorities. In such cases, we cannot control the security those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.
11. Hyperlinks directing to third-party websites
The website contains links to third-party sites and applications. These applications and websites are not under the Company's control. We are not responsible for the collection or processing of Personal Data by these websites or applications. This Policy does not apply to activities carried out through such sites or applications.
Before accessing or using any third-party website or application, we recommend that you read its privacy policy. We also advise caution before providing them with any Personal Data.
12. Changes to This Policy
When accessing any third-party websites or applications, we recommend reviewing their privacy policies before you decide to access or use them, and before providing them with any Personal Data.
13. Your rights regarding your personal data
You have the right to ask us to confirm the accuracy of the Personal Data we hold about you, correct any errors, and delete any Personal Data we no longer need. You may also restrict the scope of how your personal information is processed.
If you reside in the EEA, please refer to this page:
These rights apply to the information you have provided in relation to your Personal Data. To exercise your rights, you may submit a request by email to the address below.
Right of access
The Company can confirm whether your Personal Data is being processed. If it is, you may access that Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. If you request it, the data will be provided electronically.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request harms another person's rights or freedoms, the Company may refuse to fulfill it or limit the extent to which it is fulfilled.
Right to rectification
The Company has the right to correct inaccurate Personal Data. Taking the purpose of processing into account, you have the right to request that incomplete Personal Data about you be completed.
Right to erasure
The following grounds apply: (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 and for reasons specific to your situation, to the processing of your Personal Data based on legitimate interests pursued by us or a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be removed for the Company to comply with a legal obligation.