Privacy Policy
Last update: 09.06.2026
We (referred to as "We", "Us", or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website Thorn Fondwell (the "Website").
We uphold the following principles:
To be transparent about how we collect and process your personal information:
We want you to make informed choices about how Personal Data is used and processed. That is why we created our website, using a range of methods and procedures to give you clear information about the use of Personal Data.
If we believe you need specific details, we will provide them at the appropriate time.
We are glad to answer your questions and offer any clarifications you require, subject to limitations imposed by law. You can reach us by email at the address below: info@thorn-fondwell.com
Personal Data will be used only for the purposes set out in this Policy.
We may process your personal data for a range of purposes, including to provide the website to you, to connect you with third-party trading platforms (the 'Services'), to improve the site, to protect our rights and interests, to support the maintenance and provision of the Services, to meet regulatory or legal obligations, and to carry out the administrative and business activities that enable us to deliver the Services.
We also process your personal data to better understand your preferences and needs.
To exercise key tools that protect your rights regarding Personal Data:
To support the exercise of your rights, we have dedicated substantial resources. Contact us at any time to request access to your personal data. We can modify or delete it, stop using it for specific or general purposes, or transfer it to you or to a third party. We will accommodate your requests wherever possible.
Secure your Personal Data:
While we cannot guarantee complete security of your Personal Data, we will continue to apply a range of methods and techniques to keep your Personal Data protected.
This concludes our Privacy and Security Policy.
1. The Scope?
This policy explains the types of Personal Data the Company collects from natural persons and how it processes, shares, and secures that data.
This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly or through a combination of additional information we hold or can access.
Under this Policy, "processing" means 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 anyone under the age of 18. We do not knowingly seek or gather information from anyone younger than 18, and we do not knowingly permit such persons to use our services. If we learn that we hold information about a child, we will erase it as quickly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels or visit our website, we collect Personal Data. In some cases, we request your Personal Data directly. In others, we collect it by analysing how you use our Services or service channels, or by receiving information from our third-party partners.
3. You are not required to disclose personal information to the company, and the consequences of declining to do so.
You are not obliged to provide Us with any Personal Data. However, withholding it may prevent Us from delivering the Services or granting you access to the website.
4. What Personal Data do We collect? When you visit our website, we collect the following personal data:
This includes your online activity log, traffic data (including IP address, date of access, and time of access), the language you used, software crash logs, the type of browser used, and information about the device you used. This information is not private and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide when you connect with a third-party online trading platform through Us.
Personal data you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
The Company processes your Personal Data for the purposes described in this section, relying on the legal basis applicable to each.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on 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 need to process your data to serve a legitimate interest, such as improving Our Services or defending legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us by email for more details on the processing necessary to safeguard our legitimate interests.
Below are the reasons and legal grounds on which we may rely when using the information you provide. Personal Data.
Scope
Legal Basis
To share your personal information with third parties at your request to access digital trading
When you request it, we may collect Personal Data from you to forward to third-party companies.
You have consented to 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 to serve the legitimate interests of the Company or those of a third party.
To comply with any legal obligation or administrative, judicial, or legal requirement, Personal Data is processed to meet applicable legal requirements.
Processing is necessary to comply with our legal obligations.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any crash or malfunction reports 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 those of a third party.
6. To carry out and manage activities consistent with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.
The legitimate interests of the Company or a third party require processing.
7. To conduct analysis, such as statistical analysis
We apply various analytical methods, including statistical techniques, to inform our decisions on different matters.
Processing is necessary for 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 may process Personal Data to establish and defend legal claims and to protect our rights, interests, and assets, or those of a third party, in accordance with any applicable laws, regulations, agreements, terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Parties
We may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and analysis of user experiences.
You may also ask us to share specific Personal Data about you with third-party trading platforms. In these cases, we will provide the Personal Data you give us to those third-party trading platforms. Your Personal Data will then be subject to their privacy policies, and may be shared with multiple trading platforms.
We may share Personal Data with related entities or business partners. This gives us the resources to enhance and improve the products and services we provide to our customers.
Where necessary to safeguard the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, where such a 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 advertisers on our website or analytics companies, may also be used. These companies may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your user experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are temporarily downloaded to your device and last only briefly, until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the website recognize you as a returning user and make it easier for you to return.
Types of Cookies:
We may use them based on their purpose:
The type of cookie
These cookies are strictly necessary.
Scope
These cookies enable you to access the features you have requested and navigate our website. They deliver the information, products, and services you have asked us to provide.
They are required for your device to download and stream data, allowing you to move around the website, use its features, and return to pages you have visited before.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm that you are logged in to the site. These are deleted once you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you on each visit and remember your preferences.
Additional Information
Cookies collect personal data such as your username and last login date to confirm that you are signed in. Session Cookies are deleted once you close your web browser.
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on the site's performance, support ongoing improvements, and conduct analysis of our website.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you need to adjust your browser's settings. Below are links to guide you through the process for several of the most popular 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 expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. Retention of Your personal data
We will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
We will share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to confirm that it is still needed.
9. Transfers of personal information to a third-party country or international organisation
Your personal data may be transferred to other countries, including a third country (a country other than the one in which you reside) or to international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that users can assert their rights and access effective legal recourse.
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 an adequate level of protection for 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 under a legally binding and enforceable agreement between public bodies or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses 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.
We can share details about the security measures used to protect your Personal Data when it is transferred to third-party countries or international organisations. To request this information, email us at info@wealthwaydigital.uk
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to safeguard Personal Data, including protection 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 be held accountable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but 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 or other obligations beyond our control apply, we may be required to provide Personal Data concerning you to third parties, such as public authorities. In these situations, we cannot control the level of security applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you transmit to Us through the internet.
11. Hyperlinks to third-party websites
The website contains links to third-party sites and applications. These sites 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, and this Policy does not apply to actions taken through them.
Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also recommend exercising caution before providing any Personal Data to them.
12. Changes to This Policy
Before you access any third-party website or app, we recommend reading their privacy policy before deciding to use it. We also suggest reviewing how they handle any Personal Data you provide to them.
13. Your rights regarding your personal information
You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also restrict the scope of how your personal information is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, please send an email to the address below.
Access rights
The Company can confirm whether Personal Data about you is being processed. If it is, you may access that 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 a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.
Right to rectification
The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right to Erasure
The following grounds apply: (a) the Personal Data is no longer required 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, on grounds relating to your particular situation, to the processing of Personal Data about you 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 of the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation required 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 may ask the Company to restrict the processing of it.
Where you request that Personal Data be restricted, the Personal Data may only be retained with your consent, or to establish, exercise, or defend legal rights, to protect 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
Where processing is carried out by automated means and is based on consent or a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You have the right to request that your Personal Data be transmitted directly from the Company to another controller, where 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 affect the rights or freedoms of others.
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 on those legitimate interests. If we can demonstrate compelling legitimate grounds for the processing, we may continue unless you can show that your