Privacy Policy
Last update: 06.04.2026
We (also known as "We", "Us" or "Our") are committed to protecting your personal data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the website Thorn Kapstedham (the "Website").
These principles will be upheld:
To be transparent about how we process and collect your personal information:
We want to ensure you can make informed decisions about how your Personal Data is used and processed. That's why we've created this website. We employ various methods to provide you with relevant information about Personal Data handling. If we believe you need specific details, we'll provide information at the appropriate time. We're happy to answer any questions you may have and will provide clarifications regarding any legal limitations that apply. You can reach us via email at: info@thorn-kapstedham.com
Your personal data will only be used for the purposes outlined in this Policy.
Personal Data may be processed by us for various purposes, including providing access to the website and connecting you with third-party trading platforms (the 'Services'), improving site functionality, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal requirements, and conducting administrative and business activities necessary for the provision and use of the Services.
We also process your Personal Data to better understand your preferences and requirements.
To help you exercise your rights regarding your personal data using essential safeguards:
To help you exercise your rights, we have substantial resources available. Contact us at any time to request your personal data or to learn how we handle it. We can modify or delete your information, cease using it for specific or general purposes, transfer it to you or a third party, and accommodate any other requests you may have.
Protect Your Personal Data:
Whilst we cannot guarantee absolute security of your Personal Data, we remain committed to employing a range of methods and techniques to safeguard it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy outlines the types of personal data we collect from individuals and how we process, share, and protect it. This policy applies to information relating to an identified or identifiable natural person. An identifiable individual is someone who can be directly identified or recognised through a combination of information we hold or can access. We define "processing" as any activity involving the use or collection of personal data, including its management, organisation, and storage. Our services are intended for general audiences and are not designed for use by anyone under 18 years of age. We do not knowingly collect information from or permit use of our services by anyone under 18. Should we become aware of any personal data relating to a child, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you access our services and channels or visit our website, we collect your Personal Data. We may request your Personal Data directly in certain circumstances, or we may gather it by analysing your use of our Services and channels, or by receiving information from our third-party partners.
3. There is no requirement to disclose personal information to the company, nor are there any associated consequences.
However, you are not obliged to provide us with any personal data. In certain circumstances, the failure to supply us with personal data may prevent us from offering our Services or restrict your access to the website.
4. What Personal Data Do We Collect? When you visit our website, we gather the following personal information:
This includes information about your online activity log, traffic data (including your IP address, access date, access time, and browser type), the language you used, software crash logs, device information, and related technical details. The information collected is not private information and cannot be used to identify you.
Personal Data We Receive From You: any personal data you provide to us at your own discretion when you connect with an online trading platform of a third party through us.
Personal Information You Provide to Third-Party Platforms: this information includes your full name, address, telephone number, and email address, provided specifically to facilitate trade on their service.
5. Legal Basis and Reasons for Processing Personal Data
Your personal data is processed by the company for the purposes outlined in this section and in accordance with the applicable legal basis. Without a legal basis, the company cannot process your personal data. The legal grounds upon which the company may process your personal data are as follows:
- You have consented to the processing of your personal data for one or more purposes. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing in order to fulfil their legitimate interests. For example, this may be necessary to improve our Services or to defend legal claims.
- Processing must comply with legal requirements.
Contact us via email for further details about the processing required to protect our legitimate interests.
Below is a list of the reasons and legal grounds on which we may use the information you provide. Personal Data.
Scope
Legal Basis
We may share your personal information with third-party companies if you request it to gain access to digital trading services.
You have consented to the processing of your personal data for one or more purposes.
2. To respond to your requests, questions or concerns
We need your Personal Data to help us address any questions you may have about the Services.
We need to process personal data to protect the legitimate interests of the Company or a third party.
3. To fulfil legal or administrative requirements – Personal Data is processed to meet applicable legal obligations and judicial requirements.
To meet legal requirements, processing must be completed.
4. To enhance Our Services, Personal
Data may be used by us to improve Our Services. This includes, amongst other things, any crash or malfunction reports that we collect in relation to the Services.
We need to process personal data in order to pursue the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of our services
The Company or a third party has a legitimate need for the processing of personal data.
6. To perform and manage actions that align with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and related operations.
We need to process personal data based on the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We employ different analytical techniques, including statistical methods, to inform our decision-making on various matters.
We need to process personal data to pursue the legitimate interests of the Company or a third party.
8. To protect our assets, rights and interests, as well as those of third parties, we have developed processes to establish and defend legal claims
We may process your Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements and our terms and policies.
The Company's legitimate interests or those of a third party require the processing of your information.
6. Transfer of Personal Data to Third Parties
The Company may share your Personal Data with third-party service providers, such as hosting and storage providers, as well as to analyse user experience and IP address information.
You may request that we disclose your Personal Data to third-party trading platforms. Where you do so, we will provide your Personal Data to those platforms in accordance with their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners to provide us with the resources necessary to enhance and improve the products and services we offer to our customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory authorities, local authorities, or other official bodies.
We may additionally share your Personal Data with potential investors or buyers, lenders to the Company, or other entities within our group of companies in connection with any transaction (including the transfer or sale of Company assets or assets of any group entity) or as part of any merger, consolidation, restructuring, or insolvency of the Company or any other group entity.
7. Third-party cookies and services
Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit the website. We use cookies to collect information about your preferences and browsing habits, allowing us to enhance your experience, remember your settings, and personalise the products and services we offer. Cookies are also used for statistical and analytical purposes.
We use two main types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device for a set period after you close your browser. These help us recognise you as a returning visitor and enable you to return to the website more easily.
Types of Cookies:
They may be used by us based on their purpose:
The type of cookie
Cookies are essential
Scope
These cookies are essential for enabling you to access the features you've requested and navigate our website. We use them to deliver the information, products, and services you've asked for.
They're required for your device to download and stream data, allowing you to move through the website, use its features, and return to previously visited pages.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm that you're logged in to the site. They are automatically deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognise you on each visit to our site and remember your preferences.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you're logged in to the site. They're automatically deleted when you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data about site performance and help improve your experience. They also enable us to analyse how our website is used.
Additional Information
Cookies store anonymous data that isn't associated with any identifiable person. Some cookies are removed when you close your browser, whilst others remain valid indefinitely.
Cookies are blocked, or removed
To block or remove cookies, adjust your browser's settings. Below are links to guide you through the process for some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please be aware that certain functions or features of the Website may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service currently does not support do-not-track signals.
8. The retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing, as described in this Policy, or for longer periods as permitted by law, regulations, and applicable orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it remains necessary.
9. Transfers of personal information to third-party countries or international organisations
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country, or an additional country other than the one in which you reside, or to international organisations or jurisdictions). The Company takes all necessary steps to safeguard the personal data you provide and ensure that data users have the ability to assert their rights and access effective legal remedies.
These protections and safeguards are available to all those who reside in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection of Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was completed in accordance with the standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. You can view the clauses adopted by the EU Commission 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 employs to protect your Personal Data when transferred to third-party countries or international organisations. Please contact us at info@wealthwaydigital.uk for further details.
10. Security of Personal Data
We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without any issues. We are not responsible for indirect, incidental, or consequential losses arising from the use or disclosure of Personal Data, including cases where Personal Data is disclosed due to transmission errors, unauthorised third-party access, or other circumstances beyond our control. Where required by law or other obligations beyond our control, we may be obliged to disclose Personal Data about you to third parties, such as public authorities. We cannot control how such third parties protect your Personal Data in these situations. Data cannot be transmitted over the internet with complete certainty of security. We cannot guarantee the security of Personal Data you transmit to us via the internet.
11. Hyperlinks to third-party websites
The website contains links to third-party sites and applications that are not operated by the Company. We are not responsible for how these external websites or apps collect or process your personal data. This privacy policy does not apply to activities conducted through such third-party platforms.
Before accessing or using any third-party website or application, we recommend that you review their privacy policies. We also advise you to exercise caution when providing personal data to these external services.
12. Changes to this Policy
When visiting any third-party websites or apps that we recommend, we encourage you to read their privacy policies before deciding to access or use them. We also suggest that you review how they handle any personal data you choose to share.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of Personal Data being collected about you, rectify any inaccuracies, and delete all Personal Data no longer required by us. You may also restrict the scope and types of processing of your personal information.
If you are a resident of the EEA, please refer to this page:
These rights are accessible to you in relation to the information you provide concerning your Personal Data. You may request to exercise these rights by sending an email to the address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. If accurate, you are able to access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request would be detrimental to the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.
Right to erasure
The following reasons are applicable: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to process; (c) You object at any time, based on a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued either by us or by a third party; (d) Personal Data are unlawfully processed; or (e) Personal Data must be removed to comply with a lawful obligation.
This right does not apply if processing is necessary (a) to fulfil an obligation imposed by law under European Union or Member State law; or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you can ask the Company to restrict its processing.
If you request that Personal Data be restricted, it may only be retained if you give consent or in order to establish, exercise or defend legal rights, or to protect 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
If processing is carried out by an automated system and is based on consent or a contract to which you are party, you have the legal right to review your Personal Data that you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, if technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not interfere with the rights or freedoms of anyone else.
Right to object
You have the right at any time to object to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on these legitimate interests. If we can establish compelling legitimate grounds for processing Personal Data, we will not be able to continue processing unless you can demonstrate that they are outweighed by your rights, freedoms, or interests, or the establishment, exercise or defence of legal rights.
Concerning direct marketing: You have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent for us to process Personal Data about you at any time. This will not affect the legality of any processing that was dependent on your consent prior to withdrawal.
You are entitled to lodge a complaint with the supervisory authority in your jurisdiction.
You may lodge a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
We will provide you with the information you have requested pursuant to your rights under section 13 within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons.
Unless it contravenes the provisions of section 13, the information you request pursuant to your rights under section 13 will be provided at no cost. If the request is manifestly