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 Ledgerholm (the "Website").
These 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 your Personal Data is used and processed. That's why we've created this website. We use various methods to provide you with relevant information about Personal Data handling.
If we believe you need specific details, we'll provide them at the appropriate time.
We're happy to answer any questions and provide clarifications on any legal limitations affecting your data. Please contact us via email at: info@ledgerholm.com
Your personal data will be used only for the purposes outlined in this Policy.
Personal Data may be processed by us for a range of purposes, including offering the website and connecting you with third-party trading platforms (the 'Services'), enhancing site functionality, protecting our rights and interests, maintaining and providing the Services, meeting regulatory and legal obligations, and conducting administrative and business activities necessary for delivering and using the Services.
We also process Personal Data to better understand your preferences and needs.
To make full use of important tools that protect your rights regarding your Personal Data:
To help you exercise your rights, we have substantial resources at your disposal. 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 it 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 are committed to employing a range of methods and techniques to help protect it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy outlines the types of Personal Data the Company collects from natural individuals and how it processes, shares, secures, and manages that data.
This Policy addresses information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or identified through a combination of information we hold or can reasonably access.
The Policy defines "processing" as any activity involving the use or collection of Personal Data, including management, 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 anyone younger than 18, nor do we permit such individuals 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 Hold About You?
When you access our services and channels or visit our website, we collect your Personal Data. We may ask for your Personal Data in certain cases, or we may gather it by analysing your use of our Services and channels, or by receiving information about you from our third-party partners.
There is no requirement to disclose personal information to the company or any associated consequences.
However, you're not obliged to provide us with any personal data. In certain circumstances, if you choose not to supply us with personal data, we may be unable to offer our Services or allow users to access 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, access date, access time, and browser type), language preferences, software crash logs, device information, and 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 to us at your own discretion 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.
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 and in accordance with the applicable legal basis.
The Company cannot process your Personal Data without a valid 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 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 pursue legitimate interests, such as improving Our Services or defending legal claims.
- Processing must comply with legal requirements.
Contact us by email for further details about how we process and protect your legitimate interests.
Below is a list of the reasons and legal grounds we may use your personal data for.
Scope
Legal Basis
To provide your personal information to third-party companies at your request for access to digital trading
If you ask us to, we may request Personal Data from you to share with third-party companies.
You have consented to the processing of your personal data for one or more of the stated reasons.
2. To answer your requests, questions or concerns
We need your Personal Data to address any questions or concerns you may have about our Services.
The Company or a third party's legitimate interests require the processing of personal data.
We process your Personal Data to comply with legal, administrative, and judicial obligations.
To meet our legal obligations, we must process your data.
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 personal data to pursue the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
The Company or a third party has a legitimate interest requiring the processing of this data.
6. To carry out and manage activities in accordance with Our Services requirements
This includes back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.
The Company or a third party has a legitimate interest that requires the processing of personal data.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different matters.
The Company or a third party has a legitimate interest that requires processing of this data.
To protect our assets, rights and interests—and those of third parties—we process Personal Data to establish and defend legal claims in accordance with applicable laws, regulations and agreements.
Personal Data may be processed by us to safeguard our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations, agreements, conditions, terms and policies.
We need to process personal data where it serves the legitimate interests of the Company or a third party.
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, and may collect IP address information and user experience analytics.
You can request that we disclose 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 also share Personal Data with related entities or business partners to enhance and improve the products and services we offer.
If necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, lenders to the Company, or other group companies in connection with a transaction (including any transfer or sale of Company assets or group company assets) or as part of any merger, restructuring, consolidation, or insolvency of the Company or another group company.
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 our website. We use them to gather information about your preferences and browsing habits to enhance your user experience, remember your preferences, and personalise the products and services we offer. Cookies also support statistical and analytical purposes.
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. 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 according to their intended purpose:
The type of cookie
Cookies are essential
Scope
These cookies are necessary to access the features you've requested and navigate 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, allowing you to browse the website, use its features, and return to pages you've visited before.
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 help us recognise you when you visit our site and remember your preferences.
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 deleted when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and analyse how our website is used, 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 block or remove cookies, adjust your browser settings. Below are links to help you configure the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain functions or features of the Website 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, as 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, we'll continue sharing your data for a further 12 months.
We regularly review retained Personal Data to ensure it remains necessary.
9. Transfers of personal information to third 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 organisations. Our company takes all necessary steps to protect your personal data and ensure that data users can exercise their rights and access effective legal remedies.
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 adequate protection for Personal Data under 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 adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission 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.
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. Contact us at info@wealthwaydigital.uk for details.
10. Security of Your 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 at all times. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of your Personal Data, including loss resulting from transmission errors, unauthorised third-party access, or other circumstances beyond our control.
Where required by law or other obligations beyond our control, we may be obliged to disclose your Personal Data to third parties, including public authorities. We cannot control how these third parties handle the security of your Personal Data.
No method of data transmission over the internet is entirely secure. We cannot guarantee the security of Personal Data you send to us online.
11. Hyperlinks to Third-Party Websites
The website contains links to third-party sites and applications that operate independently of the Company. We do not supervise these external platforms and cannot be held responsible for how they collect or process your Personal Data. This Policy does not apply to any activities conducted through such third-party sites or applications.
Before accessing or using any third-party website or application, we recommend reviewing their privacy policies. We also advise you to exercise caution when sharing Personal Data with these external services.
12. Policy Amendments
When visiting any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use them. We also suggest you consider what personal data you share 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 correct any errors, and to delete all Personal Data that we no longer require. 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 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 can access your Personal Data.
The Company will provide an electronic copy of your Personal Data currently being processed at no charge. We 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 the request would harm another person's rights and freedoms, the Company may refuse or limit its response.
Right to rectification
You are entitled to request that the Company correct inaccurate Personal Data. You may demand that any incomplete Personal Data concerning you be corrected, taking into account the purpose for processing.
Right to erasure
The following circumstances apply: (a) Personal Data are no longer needed for the purpose they were collected for or processed; (b) You withdraw consent and there is no other legal basis for processing; (c) You object at any time, based on a reason specific to your situation, to processing of Personal Data about you that is based on legitimate interests pursued by us or a third party; (d) Personal Data are unlawfully processed; or (e) Personal Data must be deleted to comply with a legal obligation.
This right does not apply if processing is necessary (a) to fulfil a legal obligation required 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 restrict processing.
If you request that Personal Data be restricted, it may only be retained if you give consent or to establish, exercise or defend legal rights, or to protect another person's rights, or for 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 your consent or a contract you are party to, you have the right to access your Personal Data provided to the Company.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability does not prejudice the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on these legitimate interests. If the Company can demonstrate compelling legitimate grounds for processing, we will not stop unless you can show that they are outweighed by your rights, freedoms or interests, or by the establishment, exercise or defence of legal rights.
Regarding direct marketing, you have the right to object to processing of your Personal Data at any time.
Right to withdraw consent
You may withdraw your consent for us processing your Personal Data at any time. This will not affect the lawfulness of processing that relied 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 law may limit your rights regarding Personal Data, as detailed in this section 13.
We will provide you with the information you request regarding your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months if necessary, depending on the complexity and volume of requests. We will notify you of any extension and the reasons within one month of receipt.
Unless contrary to section 13 of the law, information you request under your rights in section 13 will be provided free of charge. If your request is unfounded, excessive or repetitive, 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 further information to verify who submitted your request.