Privacy Policy
Last update: 15.04.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide through the website Clear Fundholme (the "Website").
These principles will be upheld:
To be transparent about how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created our website. To support this, we use different methods and procedures to provide you with relevant information about the use of Personal Data.
If we believe you need specific details, we will provide them at the appropriate date and time.
We are happy to answer any questions you may have and provide any clarification you require regarding any limitations imposed by law. You can reach us by email at the address below: info@clear-fundholme.com
Personal Data will be used only for the purposes specified in the Policy.
We may process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating the maintenance and delivery of the Services, complying with regulatory or legal obligations, and carrying out administrative and business activities that support the delivery and use of the Services.
Personal Data is also processed by us to better understand your preferences and needs.
To use important tools to 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 Personal Data about your personal data. We will modify or delete it, stop using it for specific or general purposes, and transfer the information to you or to a third party. We will be able to accommodate your requests.
Protect your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to use a range of methods and techniques to help protect your Personal Data.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects from natural persons and how it processes, shares with third parties, secures, and otherwise handles that data.
This Policy applies to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we have or can access.
The Policy defines "processing" as a process involving the use or collection of Personal Data. It includes the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone younger than 18 years old We do not knowingly allow such persons to use our services. We will delete any information we discover about children as quickly as possible once we become aware of it.
2. What Personal Data Do We Have About You?
When you access the service and channels or visit our website, we collect Personal Data. We may ask for your Personal Data in certain situations. In other cases, we collect your Personal Data by analysing how our Services or service channels are used, or by receiving your information from third-party partners.
3. There is no requirement to provide personal information to the company or disclose the consequences.
However, you are not required to provide Us with any Personal Data. In some circumstances, however, you may choose not to provide Us with any Personal Data. This may prevent Us from providing the Services or prevent users from accessing the website.
4. What kind of Personal Data can We collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including your IP address, the date of access, the time of access, and the date of access), the language you used, software crash logs, the type of browser used, as well as information about the device you utilized. The information collected is not private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to provide to Us when you connect with a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
Your Personal Data is processed by the Company for the purposes described in this section, and in accordance with the legal basis applicable to it.
Without a legal basis, the Company cannot use Personal Data concerning you. The legal grounds on which the Company is able to process Personal Data regarding you:
- You have consented to the processing of your Personal Data for one or more reasons. 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 require processing to satisfy their legitimate interests. For example, this may be necessary to improve Our Services or defend legal claims.
- Processing is required to comply with a legal obligation.
Contact us by email for more information about the processing required to protect legitimate interests.
Below is a list of reasons and legal grounds for which we may use the information you provide to us. Personal Data.
Scope
Legal Basis
To provide your personal information to third parties at your request to access digital trading
If you request it We may ask you for Personal Data to share with third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is required to help address any questions you may have about the Services.
The legitimate interests of the Company or those of a third party must be processed.
3. Personal Data is processed to meet any legal, administrative, or judicial obligation and comply with legal requirements.
Processing is necessary to comply with legal obligations.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash or malfunction reports we collect in relation to the Services.
The legitimate interests of the Company or those of a third party must be processed.
5. To prevent fraud and misuse of Our Services
The legitimate interests of the Company or those of a third party must be processed.
6. To carry out and manage activities aligned with the requirements of Our Services
These activities include back-office functions, business development efforts, strategic decision-making, oversight mechanisms, etc.
The Company's legitimate interests or those of a third party need to be processed.
7. To carry out analysis, including statistical analysis
To make decisions on various issues, we use different analytical techniques (including statistical methods).
The Company's legitimate interests or those of a third party need to be processed.
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
Personal Data may be processed by us to protect our rights, interests and assets, or those of third parties, in compliance with any applicable laws, regulations or agreements and any conditions, terms or policies.
The legitimate interests of the Company or of a third party must be processed.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information services, and user experience analysis.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will provide the Personal Data you have given us to those third-party trading platforms. The use of your Personal Data will be subject to their 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. This may provide the Company with the resources it needs to enhance and improve the products and services it offers to its customers.
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 Personal Data about you with potential investors, buyers, or lenders to the Company or to any other company in the group if the same 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 those that provide advertisements on our website or analytics companies, may be utilized. These companies may also utilize cookies or other technology.
Cookies are small text files placed on your device each time you visit or access the website. Cookies are used to collect information about your preferences and browsing habits to improve your user experience, remember your preferences, and customize the products and services you may enjoy. Cookies are also utilized for statistics and analytics.
Certain cookies we may make use of are session cookies. They are temporarily downloaded to your device and last for a short period of time before you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They are utilized to help the Website identify you as a returning user and enable users to return to the website.
Types of Cookies:
They may be used by us depending on their purpose:
The cookie type
Cookies are essential
Scope
These cookies are necessary to access the features you’ve requested and to navigate our website. Cookies are used to provide the information, products and services you have asked for.
They are required for your device to download and stream data. This allows you to navigate the website, use its features, and return to pages you’ve previously visited.
Additional Information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are logged in to the site. They are deleted when you close your web browser (session Cookies).
The cookie type
Functionality Cookies
Scope
Cookies let us recognize you each time you visit our site and save your preferences.
Additional Information
Cookies collect Personal Data, including your username and the date of your last login, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
The cookie type
Cookies for performance
Scope
Cookies are used to collect statistical data about the site's performance and help improve it. They also allow Us to analyze our website.
Additional Information
Cookies store anonymous data that is not associated with any identifiable or identified natural person. They can be removed when you close your browser. Other cookies have indefinite validity.
Cookies are blocked or have been removed
To block or remove cookies, you need to change your browser settings. Below are links to help you do this for some of the most common browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all Website functions and features may not work as you expect if this happens.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of personal data about You
The Company will retain your Personal Data for as long as necessary to fulfill the purpose of processing Personal Data, as described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you agree to this, we will continue sharing your data for another 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfers of personal information to third countries or international organisations
Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country (i.e. a country other than the one in which you reside) or to international organizations). The Company takes all necessary steps to protect the Personal Data you provide and to ensure that users are able to 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 organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with article 45(3) of Regulation 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, enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be found 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 used to protect your Personal Data transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk
10. Personal Data Security
We have taken appropriate organizational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held liable 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, unauthorized access by a third party, or any other cause beyond our control.
In the event of legal obligations or other circumstances beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. We cannot control the security provided for your Personal Data by third parties in these situations.
Personal Data cannot be transferred over the web in a completely secure way. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to third-party websites
The website may include 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. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party website or app, We recommend reading their privacy policies before deciding to access or use them. We also recommend that you provide them with any Personal Data.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use their apps. We also suggest providing them with any Personal Data.
13. Your rights regarding your personal information
You have the right to ask us to confirm whether Personal Data concerning you is being collected, to correct any errors, and to delete any Personal Data that is not required by Us. You may also restrict certain types of processing of personal information.
If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the information you provide in relation to your Personal Data. You may request to exercise your rights by sending an email to the address below.
Access rights
The Company can confirm whether Personal Data concerning you is being processed. If so, you are entitled 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 any additional copies. The data will be provided electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with the request or may limit its ability to fulfill it.
Right to rectification
The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of processing.
Right to Erasure
The following reasons apply: (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 legal basis for processing; (c) You object at any time, for reasons relating to your particular situation, to the processing of Personal Data concerning you based on legitimate interests pursued either by Us or by a third party; (e) Personal Data are processed unlawfully or f) Personal Data must be deleted 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 that requires processing 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 limit the processing of your Personal Data.
If you request that Personal Data be restricted, the Personal Data may only be stored if you give consent or for the purpose of establishing, exercising or defending legal rights, or protecting 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
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 review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by the exercise of your right to data portability. The right to data portability does not interfere with the rights or freedoms of others.
Right to challenge
You have the right at any time to object to the use of Personal Data concerning you where it is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on those legitimate interests. If we are able to demonstrate compelling legitimate grounds for processing Personal Data, we may continue processing unless you show that your rights, freedoms, or interests override those grounds, or unless the processing is for the establishment, exercise or defense 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 refuse consent
You may withdraw your consent for Us to process Personal Data concerning you at anytime. This will not affect the legality or lawfulness of any processing based on your consent before it was withdrawn.
You are entitled to lodge a complaint with the supervisory authority responsible for 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 described in this section 13.
We will provide you with the information requested under the rights set out in 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 nature of the request and the number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
As long as it is not contrary to the provisions of section 13 of the law, the information you request under your rights in section 13 will be provided free of charge. If the request is unjustified or excessive, particularly if repeated, We may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.
If we have doubts regarding the identity of the actual person who submitted your request If we have doubts about the identity of the person making the request, the Company may ask for additional information.