Noble Sparmere

Privacy Policy

Last update: 30.06.2026

We 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 website Noble Sparmere (the "Website").
The following principles apply:

We are committed to being transparent about how we collect and process your personal information.

We want you to have the information you need to make informed decisions about how your Personal Data is used and processed. Our website is designed with that goal in mind, and we use a range of methods to keep you informed about how your Personal Data is handled.
Where specific details are required, we will provide them at the appropriate time.
We welcome any questions you may have and are happy to clarify any limitations imposed by law. You can reach us by email at: info@noblesparmere.com

Your personal data will only be used for the purposes outlined in this Policy.

We process your personal data to provide the website and connect you with third-party trading platforms (the "Services"), improve the site, protect our rights and interests, maintain and deliver the Services, meet regulatory and legal obligations, and carry out administrative and business activities supporting the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights over your Personal Data, you have access to the following tools:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We are committed to accommodating your requests.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we are committed to employing a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This Policy describes the types of personal data the Company collects from natural individuals, and how that data is processed, shared with third parties, and secured. This Policy applies to information relating to an identified or identifiable natural person. A natural person is considered identifiable when they can be identified directly or through a combination of additional information the Company holds or can reasonably access. "Processing" refers to any operation involving the use or collection of personal data, including its organization, structuring, and storage. Our services are intended for general audiences aged 18 and above. We do not knowingly solicit or collect personal data from anyone under 18, nor do we permit such individuals to use our services. If we become aware that personal data has been collected from a minor, we will delete it promptly.

2. What Personal Data Do We Have on You?

When you access our Services, service channels, or website, we collect personal data. This may happen directly — when you provide it to us — or indirectly, through analysis of how you use our Services or by receiving your information from third-party partners.

You are not required to disclose personal information to the company. However, choosing not to do so may limit our ability to provide our Services or grant you access to the website.

You are not required to provide us with any personal data. However, withholding it may prevent us from delivering our Services or granting you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes data about your online activity, traffic information (such as IP address, access dates, and access times), language settings, software crash logs, browser type, and device details. This information is non-personal and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide when connecting with a third-party online trading platform through Us.
Personal information you provide to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data We process your personal data only when we have a valid legal basis to do so. The specific legal basis depends on the type of personal data involved and the context in which it is collected. In general, we process your personal data on the following grounds: — Performance of a contract: where processing is necessary to provide our Services or to take steps at your request before entering into a contract with you. — Legal obligation: where processing is required to comply with a legal obligation to which we are subject. — Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests. — Consent: where you have given clear consent for us to process your personal data for a specific purpose. Where we rely on consent as the legal basis, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal. In some cases, providing your personal data is a statutory or contractual requirement. Failure to provide the requested data may prevent us from delivering our Services or granting you access to the website.

Your personal data is processed by the Company for the purposes described in this section, under the applicable legal basis.
Without a valid legal basis, the Company cannot process your personal data. The legal grounds on which the Company may rely to process your personal data are:

  • By submitting personal data through this Website, you consent to its processing for one or more specified purposes, including its transfer to a third-party trading platform.
  • Sometimes, the Company or a third party may need to process your data to pursue a legitimate interest — such as improving our Services or defending legal claims.
  • Processing is required to fulfill a legal obligation.

For more information on how we process personal data to protect legitimate interests, please contact us by email.
Below is an overview of the purposes and legal grounds under which we may use the personal data you provide.

Scope

Legal Basis

If requested, we may collect your personal data and share it with third-party companies to facilitate access to digital trading.

You have consented to the processing of your personal data for one or more purposes.

2. To respond to your requests, questions, or concerns
Personal data is required to address any questions you may have about the Services.

Processing data is necessary to serve the legitimate interests of the Company or a third party.

Personal data is processed to meet applicable legal, administrative, or judicial obligations.

Processing is required to meet our legal obligations.

4. To Enhance Our Services
We may use personal data to improve and enhance our Services. This includes crash reports and malfunction data collected in connection with the Services.

Processing of personal data may also be necessary to serve the legitimate interests of the Company or a third party.

To prevent fraud and misuse of our Services

Processing of personal data may also be necessary to serve the legitimate interests of the Company or a third party.

6. To carry out and manage activities required to operate Our Services
This includes back-office functions, business development, strategic decision-making, and oversight mechanisms.

Processing is required to support the legitimate interests of the Company or a third party.

7. To conduct statistical and other analysis
We use a range of analytical techniques, including statistical methods, to inform decisions across different areas of our operations.

Processing this data is necessary to serve the legitimate interests of the Company or a relevant third party.

8. To Protect Our Assets, Rights, and Interests — and Those of Third Parties We may process your Personal Data to protect 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 of personal data may be necessary to serve the legitimate interests of the Company or a third party.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties under the following circumstances: With your consent. We will share your personal data with third parties when you have given us explicit permission to do so. Service providers. We may share your personal data with trusted third-party service providers who assist us in operating our platform and delivering our services. These providers are contractually obligated to handle your personal data securely and only for the purposes we specify. Business transfers. If we undergo a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a different privacy policy. Legal and regulatory obligations. We may disclose your personal data to government authorities, regulators, or law enforcement agencies when required by law or when necessary to protect our legal rights, prevent fraud, or ensure the safety of our users. Affiliated entities. We may share your personal data with our parent company, subsidiaries, or affiliated entities, all of whom are required to honor this Privacy Policy. We do not sell your personal data to third parties. Any third party receiving your personal data is required to maintain appropriate security measures and use your data only for the purposes for which it was shared.

We may share Personal Data with third-party service providers, including hosting and storage providers, as well as companies that analyze user experience and IP address data.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be provided to those platforms as directed. Use of your Personal Data by those platforms is governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with related entities or business partners where necessary to support the enhancement and improvement of our products and services.
We may disclose Personal Data to regulatory, local, or other official authorities where required to protect the rights or assets of third parties.
We may also share Personal Data with potential investors, buyers, or lenders to the Company or any other entity within our group of companies in connection with a proposed or completed transaction — including the transfer or sale of assets, or any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. These third parties may place their own cookies on your device, collect data, or use tracking technologies in accordance with their own privacy policies. Third-party services we may use include analytics providers, advertising networks, and embedded content platforms. Each operates under its own terms, and we do not control how they collect or process your data. By continuing to use our website, you consent to the use of cookies as described in our Cookie Policy. You may manage or withdraw your cookie preferences at any time through your browser settings or our cookie consent tool. Note that disabling certain cookies may affect the functionality of some features on our website. For more information on how specific third parties handle your data, please refer to their respective privacy policies.

We may engage third-party service providers, such as advertising networks and analytics companies, to support our website. These providers may also use cookies or similar tracking technologies.
Cookies are small text files placed on your device when you visit the website. They collect information about your preferences and browsing behavior to improve your user experience, remember your settings, and tailor content and services to your interests. Cookies are also used for statistical and analytics purposes.
We use two types of cookies. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and allow the website to recognize you as a returning user, making it easier to access the website on future visits.

Types of Cookies:

We may use them based on their purpose:

Cookie types

Essential cookies only

Scope

These cookies are required to give you access to the features you've requested and to help you navigate our website. They enable your device to download and stream data, deliver the information, products, and services you've asked for, and allow you to move through the site, use its features, and return to pages you've visited before.

Additional Information

Cookies collect personal data — such as your username and last login date — to verify that you're logged in. They're automatically deleted when you close your browser (session cookies).

Cookie types

Functionality Cookies

Scope

Cookies help us recognize you when you visit our site and remember your preferences.

Additional Information

Cookies collect personal data — such as your username and last login date — to verify that you're logged in. They're automatically deleted when you close your browser (session cookies).

Cookie types

Cookies for performance

Scope

We use cookies to collect performance data and improve our website experience.

Additional Information

Cookies store anonymous data that is not linked to any identifiable individual. Session cookies are removed when you close your browser, while others remain valid indefinitely.

Cookies are blocked or removed
To block or remove cookies, adjust your browser's settings. Use the links below for step-by-step instructions for the most popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please note that disabling these settings may cause some or all Website features to work incorrectly or not at all.

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.
We will share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue to share your data for an additional 12 months.
We regularly review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Information to a Third-Party Country or International Organisation When we transfer your personal information outside the Philippines — whether to a third-party country or an international organisation — we do so only in accordance with applicable data protection requirements. Such transfers are carried out with appropriate safeguards in place to protect your personal information and ensure it receives a standard of protection consistent with how we handle it locally. If you require further details about the specific safeguards applied to any such transfer, you may contact us using the details provided in this policy.

Your personal data may be transferred to other countries or shared with international organizations outside the country where you reside. The Company takes all necessary steps to protect your personal data and ensure that you retain the right to assert your rights and access effective legal recourse.
These protections apply to all individuals residing in the EEA (European Economic Area).

  • Transfers to a third country or international organisation are permitted where the European Commission has determined, under Article 45(3) of Regulation 2016/679 (the "GDPR"), that the recipient country or organisation provides an adequate level of protection for Personal Data.
  • This transfer is made under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
  • This transfer was made in compliance with standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

To learn about the security measures used to protect your personal data when transferred to third-party countries or international organisations, contact us at info@wealthwaydigital.uk

10. Security of Personal Data We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. While we take reasonable steps to safeguard your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining protections that reflect current industry standards. Access to your personal data is restricted to personnel and authorized third parties who need it to perform their functions. All such parties are bound by confidentiality obligations. If you have reason to believe your interaction with us is no longer secure, please notify us immediately.

We have implemented appropriate organizational and technical measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that personal data will remain completely secure at all times, and we are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third-party access, or other causes beyond our control. Where required by legal or other obligations beyond our control, we may be required to disclose personal data to third parties, including public authorities. We have no control over the security measures applied to your personal data by such third parties. Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of any personal data you send to us online.

Links to Third-Party Websites

Our website includes links to third-party websites and applications. These sites and apps are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through those sites or apps. Before accessing or using any third-party website or app, review their privacy policy carefully. We also recommend exercising caution when providing your Personal Data to any third party.

12. Modifications to This Policy We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of this page. If changes are material, we will notify you by email or through a prominent notice on our website prior to the changes taking effect. Your continued use of our services after any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how we handle your information.

Before visiting any third-party website or app, read its privacy policy carefully. Only provide your personal data once you are comfortable with how it will be used.

Your Rights Over Your Personal Information You have the following rights regarding your personal information, subject to applicable law: Right to Access — You may request a copy of the personal information we hold about you and details of how we use it. Right to Correction — You may ask us to correct any personal information that is inaccurate or incomplete. Right to Deletion — You may request that we delete your personal information where we no longer have a lawful basis to retain it. Right to Restrict Processing — You may ask us to limit how we use your personal information in certain circumstances. Right to Data Portability — Where processing is based on your consent or a contract, you may request that we transfer your personal information to you or a third party in a structured, machine-readable format. Right to Object — You may object to our processing of your personal information where we rely on legitimate interests as our legal basis. Right to Withdraw Consent — Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Right to Lodge a Complaint — You have the right to raise a concern with the relevant data protection authority if you believe we have not handled your personal information in accordance with applicable law. To exercise any of these rights, contact us using the details provided in this policy. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing your request.

You have the right to request that we verify the accuracy of the Personal Data we hold about you, correct any inaccuracies, and delete any Personal Data we no longer need. You may also request that we limit the scope of how your Personal Data is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please send a written request to the email address below.
Access Rights
You may request confirmation that we are processing your Personal Data and, if so, request access to it.
We will provide an electronic copy of the Personal Data being processed. A reasonable fee may apply for additional copies. Data will be provided electronically upon request.
The right of access must not adversely affect the rights and freedoms of others. If a request would do so, we may decline or limit our response accordingly.
Right to Rectification
You have the right to request correction of inaccurate Personal Data. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose of processing.
Right to Erasure
Erasure may be requested where: (a) Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) Personal Data has been unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal rights.
Right to Restriction of Processing
If you have concerns about the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal rights, or to protect the rights of another individual, or where there is a substantial public interest within the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the right to receive the Personal Data you have provided to us in a structured, commonly used format.
You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.
Right to Object
You have the right to object at any time to the processing of your Personal Data based on legitimate interests pursued by us or a third party, including profiling based on those interests. If we cannot demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or that are necessary for the establishment, exercise, or defense of legal rights, we will cease processing.
With respect to direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
Right to Withdraw Consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to oversee the protection of individuals' rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit certain rights described in this section 13 as they relate to your Personal Data.
We will respond to requests submitted under your rights in section 13 within one month of receipt. Where necessary, this period may be extended by up to two months depending on the complexity and volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons for the extension.
Unless otherwise stated under section 13, information provided in response to your rights requests will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly where they are repetitive, we may charge a reasonable administrative fee or decline to act on the request.
Where we have reasonable doubt as to the identity of the person making a request, we may ask for additional information to verify your identity.