Privacy Policy
Last update: 09.03.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store information you provide through the website Thorn Kapsted (the "Website").
We uphold the following principles:
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 built this website. We use various methods and procedures to keep you informed about Personal Data usage.
If we believe you need specific details, we'll provide them at the appropriate time.
We're happy to answer your questions and offer any clarifications regarding legal limitations on data use. Please contact us by email at: info@thorn-kapsted.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 offering the website and Services to you, connecting you with third-party trading platforms, improving the site, protecting our rights and interests, maintaining and providing the Services, meeting regulatory and legal obligations, and carrying out administrative and business activities necessary for the delivery and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To access key tools for protecting your Personal Data rights:
To help you exercise your rights, we have substantial resources available. Contact us at any time to request access to your personal data. We can modify or delete it, stop using it for specific purposes or general purposes, transfer it to you or to a third party, and accommodate your requests accordingly.
Protect Your Personal Data:
While we cannot guarantee complete security of your personal data, we are committed to employing a range of methods and techniques to help protect it.
Our privacy and security policy is comprehensive.
1. The Scope?
This policy outlines the types of Personal Data the Company collects from natural individuals and how it processes, shares, secures, and manages that data.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or recognised through a combination of information we hold or can access.
The Policy defines "processing" as any operation involving the use or collection of Personal Data, including its management, structuring, 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 or solicit information from individuals under 18, nor do we knowingly permit such persons to use our services. Should we become aware of any information relating to children, 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 ask you to provide Personal Data directly in certain situations. In other cases, we gather your Personal Data by analysing how you use our Services or channels, or by receiving information from our third-party partners.
You have no obligation to share personal information with the company, and there are no consequences if you choose not to.
However, you're not required to provide us with any personal data. In certain circumstances, failure to supply personal data 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 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, and details about your device. This information is not classed as private data and cannot be used to identify you.
Personal Data We Receive From You: any personal information you voluntarily provide when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms to Facilitate Trading: this includes your full name, address, phone number, and email address.
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.
The Company cannot process your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This includes 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 need to process your data to pursue legitimate interests, such as improving Our Services or defending legal claims.
- Processing must comply with legal obligations.
Contact us by email for further details about the processing required to protect our legitimate interests.
Below you'll find the reasons and legal grounds we may use when processing your personal data.
Scope
Legal Basis
To provide your personal information to third parties at your request for access to digital trading
If you ask for it, we may request Personal Data from you to share with third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To answer your requests, questions or concerns
We need your Personal Data to respond to any inquiries you may have about the Services.
We need to process personal data to pursue the legitimate interests of the Company or a third party.
3. To meet legal obligations or comply with administrative, judicial, or other legal requirements, we process Personal Data as necessary.
To meet legal requirements, we must process your information.
4. To enhance Our Services, we may use Personal
Data to improve Our Services. This includes, for example, crash reports and malfunction data we collect relating to the Services.
The Company or a third party requires the processing of legitimate interests.
5. To prevent fraud and misuse of Our Services
We need to process personal data to serve the legitimate interests of the Company or a third party.
6. To carry out and oversee actions that comply with the requirements of Our Services
This includes back-office functions, business development activities, strategic decision-making, oversight mechanisms, and similar activities.
We need to process personal data to serve the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
To make decisions on various matters, we use different analytical techniques, including statistical methods.
The Company or a third party's legitimate interests require the processing of your data.
To protect our assets, rights and interests, as well as those of third parties, we process Personal Data in accordance with applicable laws, regulations and agreements. This processing enables us to establish and defend legal claims where necessary.
Personal Data may be processed by us to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations, agreements, conditions, terms and policies.
We need to process personal data to support the legitimate interests of the Company or a third party.
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, and may process IP address information and user experience analytics.
You can request that we share your Personal Data with third-party trading platforms. When you do so, we will provide your Personal Data to those platforms, and their use of your data is governed by their own 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 obtain resources that help us enhance and improve our products and services.
We may disclose Personal Data to regulatory, local, or other official authorities if required to protect the rights or assets of third parties.
We may also share Personal Data about you with potential investors, buyers, lenders to the Company, or other entities within our group in connection with a transaction (including the transfer or sale of Company assets or assets of any group company), or as part of any merger, consolidation, restructuring, or bankruptcy involving the Company or any other group entity.
7. Third-party cookies and services
Third-party services, such as advertisers and analytics providers, 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 our website. We use them to gather information about your preferences and browsing habits to improve your user experience, remember your choices, and personalise the products and services we offer. Cookies also help us with statistics and analytics.
Some cookies we use are session cookies. These are temporary and deleted from your device when you close your browser. Other cookies are persistent and remain on your device for a period of time after you close your browser. We use them to identify you as a returning visitor and help you access the website more easily.
Types of Cookies:
They may be used by us for their intended purpose:
The type of cookie
Cookies are essential
Scope
These cookies are necessary to access the features you've requested and navigate our website. We use them to provide the information, products, and services you've asked for.
They're required for your device to download and stream data, allowing you to move around 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 you're logged in to the site. They're deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and to save your preferences.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm you remain logged in to the site. They are automatically deleted when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and help improve the site. They also allow us to analyse how our website is being used.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are removed when you close your browser, whilst others remain indefinitely.
Cookies are blocked, or removed
To block or remove cookies, adjust your browser settings. Below are links to help you with the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain features or the entire Website's functionality may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of your personal data
The Company will retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods as required by applicable law, regulations, and official orders.
We'll share your information with third-party trading platforms for an initial period of 12 months. Should you consent, we will continue sharing your data for a further 12 months.
We regularly review the personal data we hold to confirm it is no longer required.
9. Transfer 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 outside your place of residence) or to international organisations and jurisdictions. The Company takes all necessary steps to protect your Personal Data and ensure that data users can 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 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 carried out 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 details about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Contact us at info@wealthwaydigital.uk for further information.
10. Security of Your Personal Data
We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures against accidental or unlawful destruction, loss or alteration.
We cannot guarantee that your Personal Data will remain secure without any errors. We are also not liable for any indirect, incidental or consequential damages resulting from the use or disclosure of your Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
We may be required by law or other obligations beyond our control to share your Personal Data with third parties, such as public authorities. We cannot control the security measures that third parties apply to your Personal Data in these circumstances.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you send to us via the internet.
Hyperlinks to Third-Party Websites
Links to third-party websites and applications are provided on our website. These external sites and apps are not under our control. We are not responsible for how these third parties collect or process your Personal Data. This Policy does not apply to activities on such sites or apps.
Before accessing or using any third-party website or app, we recommend you review their privacy policies. We also advise you to consider carefully what Personal Data you share with them.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend reviewing their privacy policies before you decide to access or use them. We also suggest exercising caution when sharing any Personal Data with them.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of Personal Data being collected about you, to correct any inaccuracies, and to delete all Personal Data no longer required by us. You may also restrict the scope and types of Personal Data processing.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide relating to your Personal Data. You may exercise these rights by sending an email to the address below.
Access rights
We can verify the accuracy of Personal Data being processed about you. If accurate, you may access your Personal Data.
We will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. The data will be made available electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If a request could harm another person's rights and freedoms, we may refuse to comply or limit our ability to fulfil it.
Right to rectification
We are entitled to correct inaccurate Personal Data. You may request that any incomplete or inaccurate Personal Data concerning you be corrected, taking into account the purpose of processing.
Right to erasure
The following reasons apply: (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 at any time, for reasons specific to your situation, to the processing of your Personal Data based on legitimate interests pursued by us or a third party; (d) Personal Data is processed unlawfully; or (e) Personal Data must be deleted to comply with a legal obligation.
This right does not apply if processing is necessary (a) to fulfil a legal obligation required under European Union or Member State law; or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask us to limit its processing.
If you request that Personal Data be restricted, it may only be retained if you give consent, or to establish, exercise or defend legal rights, or to protect another person's rights, 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 automated means and is based on your consent or a contract you are party to, you have the right to receive your Personal Data from us.
You may request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability does not interfere with the rights or freedoms of others.
Right to object
You have the right at any time to object to the processing of your Personal Data based on legitimate interests pursued by us or a third party. This includes objecting to profiling based solely on these legitimate interests. If we establish compelling legitimate grounds for processing, we may continue unless you demonstrate that your rights, freedoms or interests outweigh ours, or unless legal rights require it.
Regarding direct marketing, you have the right at any time to object to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. This does not affect the lawfulness of processing carried out before your withdrawal.
You have the right to lodge a complaint with the relevant supervisory authority.
You may appeal to a supervisory authority established by a Member State to protect the fundamental rights of individuals concerning Personal Data processing within the European Union.
European Union and Member State laws may limit your rights regarding Personal Data as detailed in this section.
We will provide the requested information relating to your rights in this section within one month of receiving your request. This timeframe may be extended by up to two months where necessary, depending on the nature and volume of requests. We will notify you of any extension and the reasons within one month of receiving your request.
Unless contrary to this section, information you request under your rights will be provided free of charge. If your request is unfounded, excessive or repetitive, we may charge a reasonable fee to cover administrative costs. We may also decline to act.
If we have doubts about your identity, we may request further information to verify it.