Privacy Policy
Last update: 13.04.2026
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 information you provide through the website Thornbury Kapsted (the "Website").
We uphold the following principles:
To be transparent about how we process and collect your personal information:
We want you to make informed decisions about how we use and process your personal data. That's why we created this website. We use various methods to give you clear information about personal data use.
If we think you need specific details, we'll provide them at the right time.
We're happy to answer your questions and explain anything about legal limits on data use. Contact us by email at: info@thornbury-kapsted.com
Your personal data will only be used for the purposes outlined in this Policy.
We process your personal data for several purposes: to provide the website and Services (including connecting you with third-party trading platforms), improve our site, protect our rights and interests, maintain and deliver the Services, comply with legal and regulatory requirements, and support our administrative and business operations. We also use your personal data to better understand your preferences and needs.
Personal Data are also processed by us in order to better comprehend your preferences and needs.
To use important tools that protect your rights regarding your Personal Data:
To help you exercise your rights, we have substantial resources available. Contact us at any time to request your personal data. We can modify or delete it, stop using it for specific or general purposes, transfer it to you or a third party, and accommodate your requests.
Secure 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 provides full details.
1. The Scope?
This policy outlines what Personal Data the Company collects from individuals and how it processes, shares, secures, and manages that data.
This Policy applies to information related 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 collection or use of Personal Data, including its organisation, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect or solicit information from persons under 18, nor do we permit them to use our services. If we become aware of any information collected from children, we will delete it promptly.
2. What personal Data Do We Have on You?
When you access our services, channels, or website, we collect your Personal Data. We may request this information directly from you, or we may gather it by analysing how you use our Services and channels, or by receiving it from third-party partners.
You are not required to disclose personal information to the company, nor will there be any consequences if you choose not to.
However, you're not required to provide us with any personal data. In certain circumstances, this may prevent us from delivering our services or allowing users to access the website.
4. What Personal Data Do We Collect? When you visit our website, we gather the following information about you:
This includes information about your online activity log, data about your traffic (including IP address, date of access, time of access, and device type), the language you used, software crash logs, and your browser type. This information is not private and cannot be used to identify you.
Personal Data We Receive from You: any personal data you provide at your own discretion when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms: information you submit directly to facilitate trading, including your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Your Personal Data
Your Personal Data is processed by the company for the purposes outlined in this section, 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 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 meet an obligation of law.
Contact us via email for further details about how we process your information to protect legitimate interests.
Below is a list of the reasons and legal grounds we may use your personal data.
Scope
Legal Basis
To share your personal information with third parties when you request access to digital trading
If you ask us to, we may collect Personal Data from you to pass on to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To answer your requests, questions or concerns
We need your Personal Data to help us respond to any questions you might 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, we process Personal Data as required by administrative, judicial, or legal authorities.
To ensure compliance with legal obligations, processing is required.
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 we collect in relation to the Services.
We need to process your personal data to serve the legitimate interests of the Company or a third party.
5. To stop 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 manage activities that align with the requirements of Our Services
This includes back-office functions, business development, strategic decision-making, oversight processes, and similar activities.
We need to process personal data to pursue the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different matters.
We need to process personal data to protect the legitimate interests of the Company or those of a third party.
To protect our assets, rights and interests—as well as those of third parties—we have developed procedures 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 conditions.
The Company or a third party has a legitimate interest that requires processing of personal data.
6. Transfer of Personal Data to Third Party
The Company may share your Personal Data with third-party service providers such as hosting and storage providers, including IP address information and user experience analysis.
You can request that we provide your Personal Data to third-party trading platforms. We will share your Personal Data with these trading platforms in accordance with their respective 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 enhance and improve the products and services we offer.
Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may share your Personal Data with potential investors, buyers, lenders, or other companies within our group in connection with corporate transactions (including asset transfers or sales), mergers, restructurings, consolidations, or insolvency proceedings affecting the Company or any group company.
7. Cookies and services from third parties
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 stored on your device each time you visit or access our website. We use cookies to gather information about your preferences and browsing habits to enhance your user experience, remember your choices and personalise the products and services we recommend. Cookies also help us gather statistics and analytics data.
Some cookies we use are session cookies. These are temporary files downloaded to your device and expire when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help us recognise you as a returning user and allow 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 absolutely necessary
Scope
These cookies are essential for accessing the features you've requested and navigating 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, enabling you to browse the site, 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 automatically 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 save 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 erased when you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and analytics about our website, helping us improve your experience.
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 prevent or remove cookies, you need to adjust your browser settings. Below are links to help you with this process for some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain Website functions and features 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 purpose of processing 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 12 months. If you consent to this, we'll continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it's no longer required.
9. Transfers of Personal Data to Third 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, meaning a jurisdiction outside where you reside) or to international organisations. Our company takes all necessary steps to protect your personal data and ensure that users can exercise their rights and access effective legal remedies.
These protections apply 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 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 data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. You can review 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 supply information about the security measures in place to protect your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk for details.
10. Security of 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 error. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of your Personal Data, including loss due to transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
Where required by law or other obligations beyond our control, we may need to share your Personal Data with third parties such as public authorities. We cannot control how such third parties secure your Personal Data in these circumstances.
Data transmitted over the internet cannot be guaranteed completely secure. The Company cannot ensure the security of Personal Data you transmit to us through the internet.
11. Hyperlinks to websites belonging to third party websites
The website contains links to third-party sites and applications that operate independently of the Company. We do not oversee or supervise these external platforms and are not responsible for how they collect or process your Personal Data. This Policy does not apply to activities conducted through such third-party sites or apps.
Before accessing or using any third-party website or application, we recommend reviewing their privacy policies. We also suggest exercising caution when providing Personal Data to external platforms.
12. Modifications to this Policy
When you visit any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use them. We also advise you to consider what Personal Data you share with them.
13. Your rights with respect to your personal information
You are entitled to request us to verify the accuracy of Personal Data being collected about you, to correct any errors, and to delete all Personal Data that we no longer require. You may also restrict how we process your personal information.
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. You may exercise these rights by sending an email to the address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. If accurate, you are able 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 additional copies. The data will be made available electronically upon request.
The 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, the Company may refuse the request or limit its capacity to fulfil it.
Right to rectification
The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete or inaccurate Personal Data concerning you be corrected, taking into account the reason for 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 other 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; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet a lawful obligation of the Company.
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 have concerns regarding 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 in order to establish, exercise or defend legal rights, or to protect the rights of another natural person, or where there is a reason 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 consent or a contract to which you are a party, you have the legal right to access and review your Personal Data 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 right to erasure is not affected by exercising your right to data portability. The right to data portability does not affect the rights or freedoms of anyone else.
Right to object
You have the right at any time to object to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes objection to profiling based solely on these legitimate interests. If we can establish compelling legitimate grounds for processing your Personal Data, we may not be able to cease processing unless you demonstrate that they outweigh 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 the Company to process Personal Data about you at any time. This will not affect the legality of any processing that was dependent on your consent before withdrawal.
You are entitled to lodge a complaint with the supervisory authority that oversees you.
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 detailed in this section 13.
We will provide you with the requested information regarding the rights set out in section 13 of this agreement 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 and the reasons within one month of receiving your request.
Unless this conflicts with section 13 of the law, the information you request pursuant to your rights under section 13 will be provided free of charge. If a request is unjustified or excessive, particularly if repeated, we may charge a reasonable fee