Privacy Policy
Last update: 02.06.2026
We (also known as "We", "Us" or "Our") are committed to safeguarding your Personal Data and your privacy.
This Privacy Policy is designed to inform you about how we collect and store the information you provide through the website Thorn Gainvale (the "Website").
We uphold these principles:
To be transparent about how we collect and process your personal information:
We want you to be able to make informed decisions about how your Personal Data is used and processed. That's why we've built this website. To support this, we use various methods and procedures to give you clear information about Personal Data usage.
If we believe you need specific details, we'll provide that information at the right time.
We're happy to answer any questions and provide clarification as needed, within any legal constraints. You can reach us by email at: info@thorn-gainvale.com
Personal Data will be used only for the purposes specified in the Policy.
We may process your Personal Data for various purposes, including providing you with the website and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory or legal obligations, and conducting administrative and business activities that support the delivery and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To use important tools that protect your rights regarding Personal Data:
To exercise your rights, we have substantial resources available. Contact us anytime to request access to your personal data. We can modify or delete it, stop using it for specific or general purposes, or transfer the information to you or a third party. We will accommodate your requests.
Protect your Personal Data:
While we cannot guarantee complete security of your Personal Data, we can assure you that we will continue to use a variety of methods and techniques to keep your Personal Data protected.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects from natural individuals and how it processes, shares with third parties, secures, and manages that information.
This Policy covers information related 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 we have or can access.
The Policy defines "processing" as any operation that involves the use or collection of Personal Data, including its management, organization, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18 years old, nor do we knowingly permit such individuals to use our services. If we become aware of any information from children, we will delete it as quickly as possible.
2. What Personal Data Do We Have on You?
When you access our services and channels or visit our website, we collect Personal Data. In some cases, we may request your Personal Data directly. In other cases, we gather your Personal Data by analyzing how you use our services and channels, or by receiving your information from our third-party partners.
3. There is no requirement to disclose personal information to the company or face any consequences.
However, you are not required to provide Us with any personal Data. In certain circumstances, if you choose not to supply Us with Personal Data, it 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 IP address, date and time of access), the language you used, software crash logs, the type of browser used, and details about the device you utilized. This information is not personal 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 a third-party online trading platform through Us.
Personal Information You Provide Directly to Third-Party Platforms for Trading Purposes: this information 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.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds upon which the Company may process your Personal Data are as follows:
- You have provided your consent for the processing of your personal data for one or more specified 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 need to process data to fulfill their legitimate interests. For example, this may be necessary to enhance Our Services or to defend against legal claims.
- Processing must meet a legal obligation.
Contact us via email for more details about the processing required to protect our legitimate interests.
Below is a list of reasons and legal grounds on which we may use the information you provide. Personal Data.
Scope
Legal Basis
1. To share your personal information with third-party service providers when you request access to digital trading
If you request it, we may collect Personal Data from you to pass on to third-party companies.
You have provided your consent for the processing of your personal data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data is necessary to help us answer any questions you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. To comply with any legal, administrative, judicial, or regulatory obligation, Personal Data is processed to meet the legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services Personal
Data may be used by us to enhance Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and oversee activities that comply with the requirements of Our Services
These activities include back-office operations, business development initiatives, strategic decision-making, oversight processes, etc.
The Company's legitimate interests or those of a third party require processing.
7. To conduct analysis, such as statistical analysis
To make decisions on various issues, we employ different analytical techniques (including statistical methods).
Processing is necessary for the legitimate interests of the Company or a third party.
8. To safeguard our assets, rights, and interests, as well as those of third parties, and to establish and defend legal claims
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in compliance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Sharing Your Personal Data with Third Parties
The Company may also share Personal Data with third-party service providers, including hosting and storage providers, IP address information services, and user experience analytics platforms.
You may request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will provide your Personal Data to these third-party trading platforms. The use of your Personal Data will be governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners. This enables the Company to access the resources necessary to enhance and improve the products and services we offer to our customers.
Where necessary to protect the rights or assets of third parties, the Company is authorized to 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 entity within the corporate group if such a transaction occurs (including the transfer or sale of assets belonging to the Company or any other entity within the group) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other entity within the group.
7. Third-party cookies and services
Third-party services, such as those that provide advertisements on our website or analytics companies, may be utilized. These companies may also use cookies or other tracking technology.
Cookies are small text files that are 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 enhance your user experience, track your preferences, and personalize the products and services that may interest you. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. They are temporarily downloaded to your device and last only for a short period before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are used to help the website recognize you as a returning user and enable you to return to the website.
Types of Cookies:
We may use them according to their intended purpose:
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary for you to access the features you've requested and to navigate our website. Cookies are used to provide the information, products, and services that you have asked us for.
They are required for your device to download and stream data. This allows you to navigate around the website, utilize its features, and then return to pages you've previously visited.
Additional Information
Cookies gather Personal Data, including your username and the date of your most recent login, to verify that you're signed in to the site. They're automatically deleted when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies enable us to recognize you on each visit to our site and save your preferences and settings.
Additional Information
Cookies gather Personal Data, including your username and last login date, to verify that you're logged in to the site. They're deleted when you close your web browser (session Cookies).
The 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 conduct analysis on our website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable individual. They can be deleted when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or removed
To prevent or remove cookies, you need to 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
Keep in mind, though, that some or all of the Website's features and functions 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 fulfill the processing purposes described in this Policy, or for longer periods as required by law, regulations, policies, or applicable orders.
We will share your information with third-party trading platforms for a period of 12 months. If you provide consent, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfers of personal information to a third-party country or to an international organisation
Your personal information may be transferred to other countries (i.e., your personal data may be transmitted to a third country—one other than the country in which you reside—or to international organizations). The Company takes all necessary steps to safeguard the personal data you provide and ensure that data subjects have the ability to assert their rights and access effective legal recourse.
These protections and safeguards are available to all individuals residing in 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 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 standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission are available for review 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 uses to protect your Personal Data when transferred to third-party countries or international organisations. Send an email to info@wealthwaydigital.uk
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will remain error-free at all times. We are also not liable for any intangible, incidental, or consequential damages resulting from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other circumstances beyond our control.
Where required by legal obligations or circumstances beyond our control, we may be obligated to disclose Personal Data about you to third parties, such as public authorities. We cannot control the level of security provided to your Personal Data by such third parties in these cases.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you send to Us via the internet.
11. Links to third-party websites
The website contains links to third-party sites and applications that are not under the Company's supervision. We are not responsible for how these external websites or apps collect or process Personal Data. This Policy does not apply to activities conducted through such sites or apps.
When visiting any third-party website or app, we recommend reviewing their privacy policies before deciding to access or use their services. We also advise exercising caution when providing any Personal Data to them.
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 services. We also suggest exercising caution when providing any Personal Data to them.
13. Your rights regarding your personal information
You have the right to request that we verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer need. You may also limit how we process your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. You may exercise these rights by sending an email to the address below.
Right of Access
We can verify the accuracy of the Personal Data we process about you. If accurate, you can access your Personal Data.
We will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. The data will be provided electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If your request would harm another person's rights or freedoms, we may refuse the request or limit how we fulfill it.
Right to Rectification
We are required to correct inaccurate Personal Data. You may request that incomplete Personal Data about you be corrected, considering the purpose of processing.
Right to Erasure
The following reasons apply: (a) Personal Data are no longer needed for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, based on your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by us or a third party; (e) Personal Data are being processed unlawfully; or (f) Personal Data must be deleted to comply with a legal obligation.
This right does not apply if processing is necessary (a) to fulfill a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Right to Restrict Processing
If you question the accuracy of your Personal Data, you may ask us to restrict processing of your Personal Data.
If you request restriction, Personal Data may only be stored with your consent or to establish, exercise, or defend legal claims, protect the rights of another person, or for reasons of significant public interest in the European Union or a Member State.
Right to Data Portability
If processing is automated and based on consent or a contract to which you are a party, you have the right to receive your Personal Data that you provided to us.
You may request that your Personal Data be transferred directly to another controller, where technically feasible. Your right to erasure is not affected by exercising your right to data portability. The right to data portability does not interfere with the rights and freedoms of others.
Right to Object
You may object at any time to processing of Personal Data about you that is based on legitimate interests pursued by us or a third party. This includes profiling based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or relate to establishing, exercising, or defending legal claims, we may continue processing your Personal Data.
Regarding direct marketing, you have the right to object at any time to processing of Personal Data about 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 lawfulness of any processing based on your consent before its withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding the processing of Personal Data in the European Union.
European Union and Member State laws may limit your rights regarding Personal Data about you, as detailed in this section 13.
We will provide the requested information regarding your rights in section 13 within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the complexity and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.
Unless otherwise specified in section 13, information provided under your rights in section 13 will be available free of charge. If your request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have doubts about the identity of the person making the request, we may ask for additional information.