Privacy Policy
Last update: 14.04.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website Thorn Capitalwick (the "Website").
These principles will be upheld:
To ensure transparency in how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created our website. To do this, we use different methods and procedures to provide you with relevant information about the use of Personal Data.
If we believe you need specific details, we will provide them at the appropriate date and time.
We are happy to answer any questions you may have and will provide any clarification you require regarding any limitations imposed by law. You can reach us by email at the address below: info@thorn-capitalwick.com
Personal Data will only be used for the purposes set out in the Policy.
We may process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the maintenance and provision of the Services, complying with regulatory or legal obligations, and carrying out administrative and business activities that support the delivery and use of the Services.
Personal Data is also processed by us to better understand your preferences and needs.
To make use of important tools to protect your rights regarding Personal Data:
To help you exercise your rights, we have dedicated resources in place. Contact Us at any time to request Personal Data about your personal data. We can amend or delete it, stop using it for specific or general purposes, and transfer the information to you or to an external party. We will do our best to accommodate your requests.
Protect your Personal Data:
While we cannot guarantee complete security of your Personal Data, we will continue to use a range of methods and techniques to help protect your Personal Data.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects about natural persons and how it processes, shares with third parties, secures, and otherwise handles that data.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through a combination of additional information that we have or are able to access.
The Policy defines "processing" as a process involving the use or collection of Personal Data. It includes the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old We do not knowingly permit such persons to use our services. We will delete any information we discover about children as quickly as possible if we become aware of it.
2. What Personal Data Do We Have About You?
If you access our service and channels, or visit our website, we collect Personal Data. We may ask for your Personal Data in certain cases. In other cases, we collect your Personal Data by analysing your use of our Services or service channels, or by receiving your information from our third-party partners.
3. There is no requirement to provide personal information to the company or disclose the consequences.
However, you are not required to provide Us with any Personal Data. In certain circumstances, however, you may choose not to supply Us with any Personal Data. This could prevent Us from providing the Services or prevent users from accessing the website.
4. What Personal Data can We collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including your IP address, the date of access, the time of access, and the date of access), the language you used, software crash logs, the type of browser used, as well as information about the device you utilized. The information collected is not private information 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 with a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.
5. The legal basis and reasons for the processing of personal data
Your Personal Data is processed by the Company for the purposes described in this section and in line with the legal basis that applies to it.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company is able to process your Personal Data:
- You have consented to the processing of your Personal Data for one or more reasons. 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 to meet their legitimate interests. For example, this may be necessary to improve Our Services or defend legal claims.
- Processing must comply with a legal obligation.
Contact us by email for more information about the processing required to protect legitimate interests.
Below is a list of the reasons and legal bases for which we may use the information you provide to us. Personal Data.
Scope
Legal Basis
To share your personal information with third parties at your request to access digital trading
If you request this, we may ask for your Personal Data to pass on to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is needed to help answer any questions you may have regarding the Services.
The Company’s legitimate interests or those of a third party need to be processed.
3. To meet any legal obligation or administrative, judicial or legal requirement, Personal Data is processed to comply with legal requirements.
Processing is required to comply with legal obligations.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash or malfunction reports that we collect in relation to the Services.
The Company’s legitimate interests or those of a third party need to be processed.
5. To prevent fraud and misuse of Our Services
The Company's legitimate interests or those of a third party need to be processed.
6. To carry out and manage activities in line with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, etc.
The Company's legitimate interests or those of a third party need to be processed.
7. To carry out analysis, including statistical analysis
To make decisions on different matters, we use a range of analytical techniques (including statistical methods).
The Company’s legitimate interests or those of a third party need to be processed.
8. To protect our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
We may process Personal Data in order to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
The legitimate interests of the Company or a third party need to be processed.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information services, and user experience analysis.
You may also ask us to provide specific Personal Data relating to you to third-party trading platforms. In these cases, we will share the Personal Data you provide to Us with third-party trading platforms. The use of your Personal Data will be subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners. This can give the Company the resources it needs to enhance and improve the products and services it provides to its customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company in the group if the same transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.
7. Cookies and third-party services
Third-party services, such as those that provide advertisements on our website or analytics companies, may be used. These companies may also use cookies or other technology.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and customise the products and services you may enjoy. Cookies are also used for statistics and analytics.
Certain cookies we may use are session cookies. These are temporarily downloaded to your device and remain for a short period until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after you close your browser. They help the Website identify you as a returning user and allow you to return to the website.
Types of Cookies:
They may be used by us according to their purpose:
Type of cookie
Cookies are essential
Scope
These cookies are required to let you access the features you've requested and navigate our website. Cookies are used to deliver the information, products and services you have asked us for.
They are needed for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
Type of cookie
Functionality Cookies
Scope
Cookies help us recognise you each time you visit our site and save your preferences.
Additional Information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
Type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow Us to analyse our website.
Additional Information
Cookies store anonymous data that is not linked to any identifiable or identified natural person. They can be deleted when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or have been removed
To enable or remove cookies, you need to change your browser settings. Below are links to guide you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all of the Website's functions and features may not work as you expect if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of personal data about You
The Company will keep your Personal Data for as long as necessary to fulfil the purpose of processing it, as set out in this Policy, or for longer periods where permitted by applicable law, regulations, policies, and orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to make sure it is no longer needed.
9. Transfers of personal information to a third country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country (i.e. an additional country other than the one in which you reside) or to international organisations. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data users are able to exercise their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with article 45(3) of Regulation 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, enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with 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 on the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk
10. Personal Data Security
We have taken appropriate organisational and technical measures to protect Personal Data. This includes preventing 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 error. We also cannot be held responsible for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, however, and is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
Where legal obligations or other circumstances beyond our control apply, we may be required to provide your Personal Data to third parties, such as public authorities. In these situations, we cannot control the security applied to your Personal Data by those third parties.
Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to third-party websites
Links to third-party websites and applications are provided on the website. These websites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such websites or apps.
When you visit any third-party website or app, We recommend that you read their privacy policies before deciding whether to access or use their apps. We also suggest that you consider before providing them with any Personal Data.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use their apps. We also suggest that you provide any Personal Data to them.
13. Your rights regarding your personal information
You are entitled to ask us to confirm whether Personal Data about you is being collected, to correct any errors, and to delete any Personal Data that is not required by Us. You may also restrict certain types of processing of personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you in relation to the Personal Data you provide. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company can confirm whether Personal Data about you is being processed. If it is, you are entitled to access your Personal Data.
The Company will provide 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 negatively affect the rights and freedoms of another person, the Company may refuse to comply with the request or may limit the extent to which it can fulfil it.
Right to rectification
The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.
Right to Erasure
The following reasons apply: (a) Personal Data is no longer required for the purpose for which it was collected or processed; (b) You withdraw consent and there is no legal basis for processing; (c) You object at any time, for reasons relating to your particular situation, to the processing of Personal Data about you based on legitimate interests pursued either by Us or by a third party; (e) Personal Data is processed unlawfully; or (f) Personal Data must be deleted to comply with the company's legal obligation.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law 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 limit the processing of your Personal Data.
If you request that Personal Data be restricted, it may only be stored with your consent or for the purpose of establishing, exercising or defending legal rights, protecting the rights of another natural person, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
If processing is carried out by automated means and is based on consent or a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right of 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 others.
Right to challenge
You have the right at any time to object to the use of Personal Data concerning you where it is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing Personal Data, we may continue doing so unless you can show that your rights, freedoms or interests outweigh those grounds, or where processing is required for 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 refuse consent
You may withdraw your consent for Us to process Personal Data about you at any time. This will not affect the legality or lawfulness of any processing based on your consent before it was withdrawn.
You are entitled to lodge a complaint with the relevant supervisory authority.
You may lodge a complaint with 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.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide you with the information requested under the rights set out in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months, if necessary, depending on the nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Provided this is not contrary to section 13 of the law, the information you request under your rights in section 13 will be made available free of charge. If the request is unfounded or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also refuse to act.
If we have doubts regarding the identity of the person who submitted your request, the Company may ask for further information.