Privacy Policy
Last update: 09.03.2026
We (also known as "We", "Us" or "Our") are committed to protecting your personal data and privacy.
This Privacy Policy outlines how we collect and store the information you provide through the website Thorn Capstead (the "Website").
The following principles will be upheld:
To be transparent about how we process and collect your personal information:
We want to ensure you can make informed decisions about how we use and process your personal data. That's why we've created this website. We use various methods and procedures to keep you informed about personal data usage.
Should we believe you need specific information, we'll provide it at the appropriate time.
We're happy to answer any questions and provide clarifications regarding any legal limitations that may apply. Please get in touch via email at: info@thorn-capstead.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 providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing site functionality, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and conducting administrative and business activities necessary for the operation of the Services.
We also process your Personal Data to better understand your preferences and requirements.
To use essential tools for protecting your rights regarding personal data:
To help you exercise your rights, we have substantial resources available. Please contact us at any time to request access to your personal data. We can modify or delete it, cease using it for specific or general purposes, or transfer the information to you or a third party. We're committed to accommodating your requests.
Protect Your Personal Data
While we cannot guarantee complete security of your personal data, we can assure you that we employ a range of methods and techniques to protect it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy explains the types of personal data we collect from individuals and how we process, share with third parties, and safeguard it. This policy applies to information relating to an identified or identifiable natural person. An identifiable person is someone who can be recognised either directly or through a combination of information we hold or can access. We define "processing" as any activity involving the use or collection of personal data, including its organisation, structuring, and storage. Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from or permit use of our services by anyone younger than 18 years old. Should we become aware of any information about children, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you access our service and channels or visit our website, we collect your Personal Data. We may request your Personal Data in certain circumstances, or we may gather it by analysing your use of our Services and service channels, or by receiving information from our third-party partners.
3. You are not required to disclose personal information to 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, you may choose not to share personal information with us. This could prevent us from delivering our services or prevent users from accessing the website.
4. What Personal Data Do We Collect? When you visit our website, we collect the following personal information:
This includes information about your online activity log, data about your traffic (including IP address, date of access, time of access and device information), the language you used, software crash logs, the type of browser used, and details regarding the device you utilised. The information we collect is not personally identifiable 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 an online trading platform of a third party through us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, telephone 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 use your Personal Data without a legal basis. 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, which we then transfer to a third-party trading platform.
- The Company or a third party may need to process your data to pursue their legitimate interests. For example, this may be necessary to improve our services or to defend against legal claims.
- Processing must comply with legal requirements.
Contact us via email for further details about how we process your information to protect our legitimate interests.
Below is a list of the reasons and legal grounds we may rely on when using the personal data you provide to us.
Scope
Legal Basis
We may request your personal information to share with third parties at your request, to help you access digital trading services.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your enquiries, questions or concerns
Personal Data is necessary to help us address any questions you may have about the Services.
The Company's legitimate interests or those of a third party require the processing of this data.
3. To fulfil legal obligations -- Personal Data is processed to meet statutory, administrative, judicial, and legal requirements.
To ensure compliance with legal requirements, processing is necessary.
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 that we collect in relation to the Services.
We need to process personal data to serve the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
We need to process your data to pursue the legitimate interests of the Company or a third party.
6. To perform and manage activities that align with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and related operations.
We need to process personal data to protect the legitimate interests of the Company or those of 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 issues.
The Company or a third party's legitimate interests require the processing of personal data.
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 your Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with all applicable laws, regulations, agreements, terms, conditions and policies.
The processing of personal data is necessary to protect the legitimate interests of the Company or those of 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, as well as to analyse user experiences and IP address information.
You may also request that we provide your Personal Data to third-party trading platforms. We will share the Personal Data you provide to us with these trading platforms in accordance with their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to enhance and improve the products and services we offer our customers.
Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory authorities, local authorities, or other official bodies.
We may also share Personal Data about you with potential investors, buyers, lenders to the Company, or other entities within our group of companies in connection with any transaction, including the transfer or sale of Company assets or assets of other group companies, or in the event of any merger, restructuring, consolidation, or insolvency affecting the Company or any other business within the group.
7. Third-party cookies and services
Third-party services, such as advertising 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 or access our website. We use cookies to gather information about your preferences and browsing habits to enhance your user experience, remember your preferences, and personalise the products and services we think you'll enjoy. Cookies also help us gather statistics and analytics data.
Some cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. We use them to 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 according to their purpose:
The type of cookie
Cookies are essential
Scope
These cookies are essential for you to access the features you've requested and navigate our website. They enable us to deliver 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 that you're logged in to the site. These are automatically deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies enable us to recognise you on each visit to our site and remember 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 automatically deleted when you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to gather statistical data on site performance and to help enhance your experience. They also allow us to conduct analysis on our website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are automatically removed when you close your browser, whilst others remain valid indefinitely.
Cookies are blocked, or removed
To block or remove cookies, 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, please be aware that certain functions and features of the Website may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service currently does not support do-not-track signals.
8. The retention of your personal data
The Company will retain your Personal Data for as long as is necessary to fulfil the purpose of processing, as described in this Policy, or for longer periods as permitted by applicable law, regulations, and official orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure 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—specifically, your personal data may be transmitted to a third country (that is, a country other than where you currently reside) or to international organisations and jurisdictions. We take all necessary steps to safeguard the personal data you provide and ensure that data users can assert their rights and access effective legal remedies.
These protections and safeguards are available to all those residing 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 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 Contractual Clauses, which were 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 information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk for further details.
10. Security of Personal Data
We have implemented appropriate organisational and technical measures to protect your Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. However, we cannot guarantee that Personal Data will remain secure without error. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including instances where Personal Data is disclosed due to transmission errors, unauthorised third-party access, or circumstances beyond our control. In certain circumstances, we may be required by law or other obligations beyond our control to disclose your Personal Data to third parties, such as public authorities. We cannot control the security measures applied by these third parties once the data is transferred. No method of internet transmission is entirely secure. The Company cannot guarantee the security of Personal Data transmitted to us over the internet.
11. Links to third-party websites
The website contains links to third-party sites and applications that operate independently of the Company. We are not responsible for how these third-party sites or apps collect or process your personal data. This privacy policy does not apply to your activity on such external platforms.
Before accessing or using any third-party website or application, we recommend that you review their privacy policies. We also advise you to exercise caution when providing personal data to them.
12. Changes to this Policy
Before visiting any third-party websites or applications, we recommend that you review their privacy policies to understand how they handle your information. 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 rectify 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 in relation to your Personal Data. You may request to exercise these rights by writing an email to the address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. If accurate, you are able to access your 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 upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request is detrimental to the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete or inaccurate Personal Data concerning you be rectified, taking into account the purpose for processing.
Right to erasure
The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected; (b) You withdraw consent and there is no 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 by us or by a third party; (d) Personal Data are unlawfully processed; or (e) Personal Data must be removed to comply with a lawful obligation.
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 restrict the processing of your Personal Data.
If you request that Personal Data be restricted, the data may only be retained if you give consent or in order to establish, exercise or defend legal rights, or to protect the rights of another individual, or in the case of a significant public interest within the European Union or a Member State.
Right to data portability
If processing is carried out by an automated system and is based on consent or a contract to which you are a party, you have the legal right to 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. The rights you have under the right to erasure do not change through exercising your right to data portability. The right to transfer data does not interfere with the rights or freedoms of anyone else.
Right to object
You have the right at any time to object to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This is not limited to profiling based solely on these legitimate interests. If we are able to establish compelling legitimate grounds for processing Personal Data, we will not be able to continue doing so unless we can demonstrate that they outweigh your rights, freedoms, or interests, or the exercise, establishment or defence of legal rights.
Concerning direct marketing, you have the right at any time to object to processing Personal Data concerning you.
Right to withdraw consent
You may revoke your consent for us processing Personal Data about you at any time. This will not affect the lawfulness of any processing that was dependent upon your consent prior to its withdrawal.
You are entitled to lodge a complaint with the supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to safeguard 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.
We will provide you with the requested information in accordance with the rights you have under this section within one month of receiving your request. This timeframe may be extended by up to two months if needed, depending on the nature and volume of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Unless otherwise provided in this section, the information you request pursuant to your rights will be made available free of charge. If your request is unjustified or excessive, particularly if repeated