Privacy Policy

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

We want you to make informed decisions about how your Personal Data is used and processed. This page explains what we do with your Personal Data and how we collect and handle it. Where specific information is relevant to you, we will provide it at the appropriate time. If you have any questions or need clarification on any legal limitations that apply, please contact us at: info@zephyrwealtode.com

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

We process your personal data for a range of purposes: to provide the website and connect you with third-party trading platforms (the "Services"), to improve the site, protect our rights and interests, to support the maintenance and delivery of the Services, to meet applicable regulatory and legal obligations, and to carry out administrative and business activities related to the Services.
We also process your personal data to better understand your preferences and needs.

To exercise your rights in relation to your Personal Data:

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 will accommodate your request accordingly.

Protect Your Personal Data:

While no system can guarantee absolute security of your personal data, we are committed to employing a range of robust methods and techniques to keep it protected.
This Privacy and Security Policy is complete.

1. The Scope?

This policy describes the types of personal data the Company collects about natural individuals, and how it processes, shares, and secures that data.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for users aged 18 and above. We do not knowingly collect personal data from, or permit use of our services by, anyone under the age of 18. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

2. What Personal Data Do We Have on You?

When you access our services, channels, or website, we collect Personal Data. Depending on the circumstance, we may request this directly from you, gather it by monitoring how our services and channels are used, or receive it from our third-party partners.

You are not required to disclose personal information to the company. However, withholding certain personal information may prevent us from delivering our Services or granting you access to the website.

You are not required to provide us with any personal data. However, choosing not to do so may prevent us from delivering the Services or restrict your access to the website.

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

This includes information collected automatically when you use our services, such as your activity log, traffic data (including IP address, access dates, and access times), language settings, software crash reports, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal Information Provided to Third-Party Platforms: information submitted directly to third-party platforms to facilitate trading, including your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data We process your personal data on the following legal bases: a) Performance of a contract — where processing is necessary to perform a contract to which you are a party, or to take steps at your request before entering into a contract. b) Legal obligation — where processing is necessary to comply with a legal obligation to which we are subject. c) 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 freedoms. d) Consent — where you have given clear consent for us to process your personal data for a specific purpose. We collect and process personal data only to the extent necessary for the purposes described in this Policy. Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Providing certain personal data is a contractual or statutory requirement. Failure to provide such data may prevent us from delivering our Services or granting you access to the website.

6. Transfer of Personal Data to Third Party We may share your personal data with third parties in the following circumstances: a) Service Providers: We engage third-party service providers to support our operations, including IT infrastructure, payment processing, customer support, and analytics. These parties are permitted to process your personal data only as necessary to perform their designated functions and are contractually required to maintain appropriate data protection standards. b) Business Partners: Where our services involve collaboration with third-party partners, we may share relevant personal data to facilitate service delivery. Such sharing is limited to what is necessary for the specific purpose. c) Legal and Regulatory Requirements: We may disclose your personal data to regulators, law enforcement agencies, or other authorities where required by applicable law or in response to a lawful request. d) Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the relevant successor entity. We will notify you of any such change and the applicable data protection arrangements. e) With Your Consent: We may share your personal data with other third parties where you have given explicit consent for us to do so. In all cases, we take reasonable steps to ensure that third parties who receive your personal data are bound by appropriate confidentiality and data protection obligations consistent with this policy.

We may share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis.
Upon your request, we will also share specific Personal Data with third-party trading platforms of your choosing. Your Personal Data shared with such platforms is subject to their own privacy policies, and may be disclosed to more than one trading platform.
We may share Personal Data with affiliated entities or business partners where this supports the development and improvement of our products and services.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any entity within its group — in connection with a transaction such as an asset transfer or sale, merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

7. Cookies and Third-Party Services We use cookies and third-party services on our website to improve functionality, analyse usage, and deliver relevant content. These third parties may collect and process certain data in accordance with their own privacy policies. By using our website, you consent to the use of cookies and third-party services as described in this section. You may manage or withdraw your cookie preferences at any time through your browser settings or our cookie management tool. However, disabling certain cookies may affect the functionality of our website. Third-party service providers we engage may include analytics platforms, advertising networks, and embedded content providers. These parties operate independently and are responsible for their own data practices. We recommend reviewing their respective privacy policies to understand how your data is handled. We do not sell your personal data to third parties. Where third-party services are used, we take reasonable steps to ensure they meet applicable data protection standards.

We may work with third-party service providers, including advertising partners and analytics companies, who may also use cookies or similar tracking technologies on our website.
Cookies are small text files placed on your device when you visit the website. They collect information about your browsing habits and preferences to improve your experience, remember your settings, and tailor the products and services shown to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies — temporary files downloaded to your device that expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognise you as a returning user and allow you to resume your session.

Types of Cookies:

We may use them based on their purpose:

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 fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulations, or orders.
Your information will be shared with third-party trading platforms for 12 months. With your consent, this sharing will continue for a further 12 months.
We periodically 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 We may transfer your personal information to recipients located outside Malaysia, including in third-party countries or through international organisations. Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal information in accordance with applicable data protection requirements. These transfers may be necessary to deliver our services, fulfil contractual obligations, or comply with legal requirements. In all cases, we take reasonable steps to ensure your personal information receives a level of protection consistent with how it is handled within Malaysia. If you require further information about the specific safeguards applied to cross-border transfers of your personal information, please contact us using the details provided in this policy.

10. Security of Personal Data We are committed to protecting your personal data and take reasonable technical and organisational measures to safeguard it against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential. Do not share your password with any third party. If you believe your account has been compromised, notify us immediately. We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required to comply with our legal obligations, resolve disputes, and enforce our agreements. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant authorities and, where required, inform you directly in accordance with applicable obligations and within the timeframes required. If you have questions about the security of your personal data, contact us at the details provided in this policy.

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 the security of your Personal Data will be maintained without error, nor can we accept liability 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, unauthorised third-party access, or other causes beyond our control. Where legal or other obligations require it, we may be required to disclose Personal Data to third parties, including public authorities. We have no control over how such third parties manage the security of your Personal Data in those circumstances. Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website may contain 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 such sites or apps.
Before accessing or using any third-party website or application, we recommend reviewing their privacy policy. We also advise carefully considering what Personal Data, if any, you choose to share with them.

12. Modifications to This Policy We may update this 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 may notify you directly — by email or through a notice on our platform. 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 their privacy policy carefully. We also recommend that you consider what personal data you share with them.

13. Your rights with respect to your personal information Depending on your location and applicable laws, you may have certain rights regarding your personal data. These may include the right to access, correct, delete, or restrict the processing of your personal data, as well as the right to object to certain types of processing or to request data portability. To exercise any of these rights, you may contact us using the details provided in this policy. We will respond to your request within the timeframe required by applicable law. In some cases, we may need to verify your identity before processing your request. Please note that these rights are not absolute. Certain legal obligations or legitimate business purposes may limit our ability to fulfill a request. Where we are unable to comply, we will explain why. If you believe your personal data has been handled in a manner inconsistent with this policy or applicable law, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

You have the right to request that we verify the accuracy of Personal Data being collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also request restrictions on the scope or type of processing applied to your personal information.
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 submit a written request to the email address below.
Access Rights
The Company can verify whether your Personal Data is being processed. If it is, you may request access to that data.
The Company will provide an electronic copy of your Personal Data currently being processed. A reasonable fee may be charged for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would be detrimental to another person's rights or freedoms, the Company may refuse or limit its 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 for which it is processed.
Right to Erasure
This right applies where: (a) the 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) the Personal Data has been unlawfully processed; or (f) the 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) for the establishment, exercise, or defence of legal claims.
Right to Restriction of Processing
If you have concerns about the accuracy of your Personal Data, you may request that the Company restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, or for the protection of the rights of another natural person, or for reasons of significant 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 on a contract to which you are a party, you have the right to receive your Personal Data in a structured 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, and 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 Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not required for the establishment, exercise, or defence of legal claims, we will cease such processing.
Regarding 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 the relevant supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State law may place limitations on the rights described in this section 13 as they relate to your Personal Data.
We will respond to requests made under the rights set out in section 13 within one month of receipt. Where necessary, given the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.
Unless otherwise provided under section 13, information provided in response to a request under this section will be supplied free of charge. Where requests are manifestly unfounded or excessive, in particular where they are repetitive, we may charge a reasonable administrative fee or decline to act on the request.
Where we have reasonable doubts about the identity of the person submitting a request, we may request additional information to confirm that identity.