Privacy Policy

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

Fortisbay Sylor collects and stores data necessary for your trading activities on our trading platform. How we collect and store this information is explained in the Privacy Policy below.

The following principles guide our policy:

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

We aim to make it clear how we collect and process your data, so you can make informed decisions. We follow clear guidelines and processes for handling data through this official website. This policy outlines the specific methods we use, providing you with clear, concrete information about its use. You remain in control.

We will always share information promptly whenever we determine you should be informed. Transparency is our priority.

Our trained support team is always available to answer any questions you may have about our processes, including our obligations under the laws of Uganda. You can contact us at info@fortisbay-sylor.com

• We do not use your personal data for any purpose beyond what is outlined in our Privacy Policy.

We may process personal data for the following purposes: to ensure the proper operation of the Fortisbay Sylor Services and to connect trader-members with third-party trading platforms; to maintain and improve our official website’s features and services; to protect our rights; and to comply with regulatory and other legal obligations. We also process personal data as needed to deliver administrative and other business functions related to the Services we provide to you, the client.

To provide better services tailored to your preferences and needs, Fortisbay Sylor uses personal data.

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

You can contact us at any time to access all the personal data we hold about you. We can also update or delete it where needed. In addition, we support requests to transfer your data to you or to a designated third party. These services are provided to help you exercise your rights to privacy and control.

• Keep your personal information secure:

We use bank‑grade security measures to protect your data. While no system can guarantee 100% safety, we continuously upgrade our infrastructure and strengthen existing controls to maintain the highest possible level of protection.

We maintain a comprehensive privacy policy and the highest-level security systems.

1. The Scope?

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

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

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

We neither collect nor attempt to collect information about anyone under 18. We also do not allow individuals under 18 to use our platform for any purpose. If we become aware of a user or any data relating to a person under 18, we will delete it immediately.

2. Which personal data do we store?

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

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

Although you are not obligated to provide your data, choosing not to do so may limit the services we can offer and restrict your use of our platform.

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

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

Regarding personal data, we collect and retain only the information you expressly consent to provide when you connect, through us, with a third party trading platform.

The personal information you have provided to third-party platforms may include your full name, address, telephone 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 set out in this Policy. All such use and processing complies with the relevant laws of Uganda.

The company will not collect, process, or transmit your data except in accordance with the applicable laws of Uganda. We rely on the following legal grounds:

• By submitting your personal data to the company, including via our official website, you consent to its storage and processing. You also authorise us to transfer your data to the relevant third-party trading platform where appropriate. Your consent applies to the processing of your personal data for one or more purposes.
• To improve our services, assert or defend legal claims, and pursue other legitimate interests, the company may need to store and process your personal data.
• Data processing is necessary to comply with legal obligations.

If you would like more information about the data processing we are legally required to perform, 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 bases.

6. Sharing of Personal Data with Third Parties

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

At your request, we may share specific personal information you provide with third-party services. In such cases, the use of your data will be governed by that company’s privacy policy. This may include one or more digital trading platforms.

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

Where required by law, or to safeguard the company’s rights and assets and those of our third-party partners, we may share data with 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 applies to any merger, restructuring, consolidation, or bankruptcy proceedings, in accordance with applicable law.

7. Cookies and Third-Party Services

In line with applicable laws and standard practice, our official website may use cookies and similar technologies for site analytics and in collaboration with advertising partners.

Cookies are small text files stored on your device when you visit our official website. We use them to understand your browsing behaviour and preferences, helping us personalise and enhance your experience. Cookies enable us to remember your settings and tailor our services accordingly. We also use them for site analytics and to compile statistics for planning and improvement.

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, allowing the site to recognise you when you return and making it easier to use.

Types of cookies:

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

Cookies are blocked or have been deleted

If you wish to delete cookies or prevent them from being set, please do so through your browser settings. Follow the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

If you block cookies, some site operations and features may not work as expected.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to support the operations described elsewhere in this policy. We may keep it longer where required by local laws and regulations or by our company policies.

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

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

Where necessary to deliver our services and/or for security reasons, we may transfer personal data to third countries (countries outside your own) and to international organisations, with full security protocols in place. We apply the highest standards of data security to safeguard your information and to ensure you can access your legal rights and remedies in all circumstances.

All residents of the EEA (European Economic Area) are protected by data protection laws and safeguards.

• All data transfers are carried out under the jurisdiction and competence of the EU, in accordance with the data protection standards 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 entities or authorities are conducted in accordance with Article 46(2) and governed by a legally binding, enforceable agreement.
• Data transfers are conducted in line with the European Commission’s Standard Contractual Clauses, as set out in 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 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 using technical and organisational measures that meet the highest standards and follow industry best practices. These measures help prevent unlawful or accidental destruction, loss, or alteration of the data.

Although we apply the highest level of care and follow best-practice procedures for data protection as required by law, we cannot guarantee that your personal data will always be error-free. Accordingly, we cannot be held liable for any disclosure or for incidental, intangible, or consequential loss or damage to personal data. This includes circumstances 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 to them. After disclosure pursuant to applicable law, we do not control how those authorities handle, store, or protect your information.

Any information sent over the internet, including personal data, may be intercepted and is not 100% secure. The Company cannot guarantee the security of any data transmitted online.

11. Links to third-party websites

This official website may contain links to third-party applications and websites. These parties are not our affiliates and operate independently; we do not control them, and our Privacy Policy does not apply to them. They have their own policies and practices for collecting and processing personal data, and we are not responsible for those activities. Use at your own discretion.

Always review the privacy policy of any company or service on its official website before providing any personal data. Ensure 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 amend this policy at any time. We will notify you of any changes via our official website and 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 your personal data

You retain full control and the final say over how your personal data is used. You may review and verify its accuracy, correct any errors, and choose to delete it or limit the scope and nature of our processing.

This page provides EEA residents with relevant information:

Your personal data is protected by the rights set out herein. You may exercise these rights immediately by sending an email to 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 therefore verifiable.

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

Rights granted by law and under this privacy policy must not be exercised in a way that infringes 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

Any errors in your personal data, whether due to omissions or inaccurate details, may be corrected by you or the Company to ensure it is processed properly.

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 grounds; 2) when you ask us to remove it and the Company has no legal obligation to retain it; 3) if you no longer agree to any processing by us, even where such processing is lawful and based on our legitimate interests or those of a third-party provider; and 4) if we are legally required to delete your data.

The right to deletion may be overridden by legal obligations under EU or any member state law. The same applies where data is required to establish, exercise, or defend legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal information 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 cases: 1) where the law of the European Union or any Member State prevents deletion; 2) with your consent, where it is necessary to defend against or pursue legal claims; 3) where deletion would infringe 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 form, to its collection and to processing by automated systems.

You have the right to request the transfer of your personal data to another company or organisation, where technically feasible. This does not affect your right to have your data deleted. We cannot grant this right where doing so would infringe the rights or freedoms of another individual.

Your right to challenge the processing of your data

Even where the Company relies on legitimate interests—its own or those of a third-party service provider—you have the right to object to the processing and request that it stop. This does not apply where there is a compelling legal basis to continue, 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 any direct marketing purposes.

Your Right to Withdraw or Refuse Consent

You can withdraw your consent to our processing of your personal data at any time and, where possible, it will take effect immediately. This will not affect any processing carried out before you withdrew consent.

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

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

Section 13 outlines the circumstances under which your personal data rights may be limited by the laws of the European Union or those 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 set out in Section 13 of this policy. We may extend this timeframe 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.

Requested information will be provided electronically at no cost, unless this would violate applicable law or the provisions of Section 13. We may charge a reasonable fee or decline to process a request that is unfounded, excessive, or repetitive.

We may require additional proof of identity if we have reasonable doubts about the identity of the person requesting personal data, to protect data and maintain security.