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 explains how we collect and store information you provide through the website Cairn Phundholm (the "Website").
We uphold the following principles:
To ensure transparency regarding how we process and collect your personal information:
We want to empower you to make informed decisions about how your Personal Data is used and processed. That's why we've created this website. We use various methods to keep you informed about Personal Data practices.
When we believe you need specific details, we'll provide that information at the right time.
We're happy to answer your questions and provide any clarifications you need regarding legal limitations. Please reach out to us by email at: info@cairn-phundholm.com
Your personal data will only be used for the purposes outlined in this Policy.
We process your Personal Data for several purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), improving site functionality, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal requirements, and conducting administrative activities to support the Services.
We also process your Personal Data to better understand your preferences and needs.
To protect your rights regarding personal data, use our comprehensive tools available to you:
To help you exercise your rights, we've dedicated substantial resources to assist you. Contact us anytime to request access to your personal data, and we'll be happy to modify or delete it, restrict its use for specific purposes, transfer it to you or a third party, or accommodate any other requests you may have.
Secure your Personal Data:
While we cannot guarantee complete security of your personal data, we are committed to employing a range of industry-standard methods and techniques to protect it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of personal data we collect from individuals and how we process, share, and secure it. This policy applies to information related to an identified or identifiable natural person—someone who can be directly identified or recognized through a combination of information we hold or can access. We define "processing" as any activity involving the collection, use, management, structuring, or storage of personal data. Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect information from minors under 18, nor do we permit them to use our services. If we become aware of any personal data belonging to a child, we will delete it promptly.
2. What personal Data Do We Have on You?
When you access our services and channels or visit our website, we collect personal data. We may request your personal data in certain circumstances, or we may gather it by analyzing how you use our services and channels, as well as by receiving information from our third-party partners.
3. You are not required to share personal information with the company, nor are there any consequences for choosing not to do so.
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. That said, doing so could prevent us from delivering our Services or limit 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 language), software crash logs, browser type, and device information. The information collected is not personally identifiable and cannot be used to identify you.
Personal Data We Receive From You: any personal data you voluntarily provide when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms: this information includes your full name, address, phone number, and email address to facilitate trading activities.
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 process your personal data. The legal grounds the company may use to process your personal data include:
- 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 information to pursue legitimate interests. For example, this may be necessary to improve our services or defend against legal claims.
- Processing must meet an obligation of law.
Contact us via email for more details about how we process your information to protect legitimate interests.
Below is a summary of the reasons and legal grounds we may use for the personal data you provide to us.
Scope
Legal Basis
To share your personal information with third parties at your request for digital trading access
If you ask for it, we may request Personal Data from you to forward to third-party companies.
You've given your consent for your personal data to be processed for one or more purposes.
2. To address your requests, questions, or concerns
We need your Personal Data to help us respond to any questions you may have about our Services.
We need to process your data to support the legitimate interests of the Company or a third party.
3. To meet legal obligations — we process Personal Data as required by applicable laws, regulations, and legal or judicial proceedings.
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.
We process personal information based on the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services
We may process your data based on the legitimate interests of the Company or a third party.
6. To perform and manage actions that align with the requirements of Our Services
This includes back-office functions, business development activities, strategic decision-making, oversight mechanisms, and related operational activities.
We must process personal information to protect 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 issues.
The Company or a third party has a legitimate interest that requires the processing of this information.
8. 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 policies.
We may process your personal information when the Company or a third party has a legitimate interest in doing so.
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, as well as to analyze user experience and collect IP address information.
At your request, we can share your Personal Data with third-party trading platforms. Your data will be provided in accordance with their privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities and business partners to enhance and improve the products and services we offer.
If necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or official authorities.
We may additionally share your Personal Data with potential investors, buyers, lenders, or other companies within our corporate group in connection with any transaction (including asset transfers or sales), merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Cookies and services from third parties
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 our website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your settings, and customize the products and services we think you'll enjoy. Cookies also help us collect statistics and analytics data.
Some cookies we use are session cookies. These are temporary files downloaded to your device and deleted when you close your browser. Other cookies are persistent—they remain on your device for a period of time after you close your browser. Persistent cookies help us recognize you as a returning visitor and allow you to resume your experience on the website.
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 necessary to access the features and content you've requested and to navigate our website. We use them to deliver the information, products, and services you need.
They're required for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you've previously visited.
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 erased when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognize you when you visit our site and allow us to 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, help improve your experience, and 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, while others remain active 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
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 as long as necessary to fulfill the purposes outlined in this Policy, or for such longer periods as required by applicable law, regulations, and court orders.
We'll share your information with third-party trading platforms for an initial period of 12 months. With your consent, we'll continue sharing your data for an additional 12 months.
We regularly review retained personal data to confirm it's no longer required.
9. Transfers of personal information to third-party countries or international organisations
Your personal information may be transferred to other countries—that is, your personal data may be transmitted to a third country (a jurisdiction outside the one where you reside) or to international organizations. We take all necessary steps to protect the personal data you provide 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 organization that the EU Commission has determined provides adequate protection of Personal Data in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and 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 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 organizations. Please reach out by email at info@wealthwaydigital.uk for more information.
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect your Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
While we make every effort to maintain security, we cannot guarantee that your Personal Data will be protected without error. We are 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, data disclosed due to transmission errors, unauthorized third-party access, or circumstances beyond our control.
In certain situations, we may be legally required or otherwise obligated to disclose your Personal Data to third parties, such as government authorities. In such cases, we cannot control how these third parties handle your information.
Data transmission over the internet cannot be guaranteed as completely secure. While we strive to protect your Personal Data, we cannot ensure its security during transmission to us.
11. Hyperlinks to websites belonging to third party websites
The website contains links to third-party sites and applications that are not controlled by the Company. We are not responsible for how these third-party websites or apps collect or process your personal data. This privacy policy does not apply to their actions or practices.
Before accessing or using any third-party website or app, we recommend reviewing their privacy policies. We also encourage you to carefully consider what personal data you share with them.
12. Modifications to this Policy
Before visiting any third-party websites or apps we recommend, we encourage you to review their privacy policies before deciding whether to access or use them. We also suggest being cautious about sharing any personal data with these platforms.
13. Your rights with respect to your personal information
You are entitled to request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete Personal Data that we no longer require. You may also restrict the types of processing we apply to your information.
If you are a resident of the EEA, please refer to this page:
These rights are accessible to you regarding the information you provide about your Personal Data. You may exercise your 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 may access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed. We may charge a reasonable fee for additional copies. 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 or freedoms, the Company may refuse the request or limit how we fulfill it.
Right to rectification
You are entitled to request that we correct any inaccurate or incomplete Personal Data concerning you, taking into account 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 legal basis for processing; (c) You object at any time to processing of your Personal Data based on legitimate interests pursued by us or a third party; (d) Personal Data are 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 fulfill a legal obligation 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 the Company to limit its processing.
If you request that Personal Data be restricted, it may only be retained if you provide consent or to establish, exercise, or defend legal rights, or to protect the rights of another individual, 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 review and receive your Personal Data from the Company.
You may request that your Personal Data be transferred directly from the Company 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 affect the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of your Personal Data based on legitimate interests pursued by the Company or a third party. This includes objecting to profiling based on these legitimate interests. If the Company can demonstrate compelling legitimate grounds for processing, we may continue only if we can show those grounds outweigh your rights, freedoms, or interests, or are necessary to establish, exercise, or defend legal rights.
Regarding direct marketing, you have the right at any time to object to processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for the Company to process your Personal Data at any time. This does not affect the lawfulness of processing based on your consent before withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding Personal Data processing within the European Union.
European Union and Member State laws may limit your rights regarding your Personal Data as outlined in this section 13.
We will provide you with the information requested under your rights in section 13 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. We will notify you of any extension and the reasons within one month of receiving your request.
Information requested under your rights in section 13 will be provided at no cost, unless it conflicts with section 13 provisions. If a request is unjustified or excessive, particularly if repeated, we may charge a reasonable fee to cover administrative costs. We may also decline to act.
If we have doubts about your identity, the Company may request additional information to verify it.