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 Fundholm (the "Website").
We uphold the following principles:
In the interest of transparency, here's how we process and collect your personal information:
We want you to have the information you need to make informed decisions about how your Personal Data is used and processed. That's why we created this website. We use various methods to keep you informed about our Personal Data practices.
When we believe you need specific details, we'll provide them at the appropriate time.
We're happy to answer your questions and provide clarifications about any legal limitations that may apply. Please reach out to us via email at: info@cairn-fundholm.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 access to our 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 requirements, and conducting administrative and business activities necessary for service delivery and use.
We also process Personal Data to better understand your preferences and needs.
To access essential tools that protect your rights regarding your Personal Data:
To help you exercise your rights, we have substantial resources available. Contact us anytime to request access to your personal data. We can modify or delete it, stop using it for specific or general purposes, transfer the information to you or a third party, and accommodate your requests.
Protect Your Personal Information:
While we cannot guarantee complete security of your personal data, we're committed to using a variety 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 we collect from individuals and how we process, share, and protect that information. Personal data refers to information related to an identified or identifiable individual—someone who can be directly identified or identified 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 management, organization, 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 information from minors and do not permit them to use our services. If we become aware of personal data belonging to a child, 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 request your Personal Data directly in certain cases, or we may collect it by analyzing how you use our services and channels, or by receiving information about you from our third-party partners.
3. There is no requirement to disclose personal information to the company, and no consequences will result from declining to do so.
However, you're not required to provide us with any personal data. In certain circumstances, if you choose not to share personal information with us, it may prevent us from delivering our services or limit your access to the website.
4. What Kind of 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 language preference), software crash logs, browser type, and device information. This data is not personally identifiable and cannot be used to identify you.
Personal Data We Receive From You: any personal information 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 your trades.
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 process your Personal Data without a valid legal basis. The legal grounds that permit the Company 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 we can transfer it to a third-party trading platform.
- The Company or a third party may need to process your information to pursue their legitimate interests. For example, this might be necessary to enhance our services or defend against legal claims.
- Processing must comply with legal requirements.
Contact us by email for more details about the processing needed to protect our legitimate interests.
Below is a list of reasons and legal grounds we may use your information for. Personal Data.
Scope
Legal Basis
To share your personal information with third parties when you request access to digital trading services
If you ask us to, we may collect Personal Data from you to forward to third-party companies.
You have consented to the processing of your personal data for one or more of the reasons listed above.
2. To address your requests, questions, or concerns
We need your Personal Data to help answer any questions you may have about our Services.
We need to process personal information to protect the legitimate interests of the Company or a third party.
3. To meet legal obligations, we process your personal data as required by applicable laws and regulations, including administrative, judicial, and other legal requirements.
To comply with legal requirements, processing is necessary.
4. To Enhance Our Services
We may use your Personal Data to improve and enhance Our Services. This includes collecting and analyzing crash reports and malfunction data related to the Services.
We need to process personal information to protect the Company's legitimate interests or those of a third party.
5. To prevent fraud and misuse of our services
We may process your information where the legitimate interests of the Company or a third party require it.
6. To perform and manage actions that align with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and related operations.
We need to process personal information to protect the Company's legitimate interests 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 has a legitimate interest that requires the processing of your information.
8. To protect our assets, rights, and interests, as well as 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, and associated terms, conditions, or policies.
The Company or a third party has a legitimate interest that requires the processing of this information.
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, to support our operations and analyze user experiences.
At your request, we can share specific Personal Data with third-party trading platforms. Your Personal Data will be provided to these platforms in accordance with their respective privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners to help us enhance and improve the products and services we offer.
We may disclose Personal Data to regulatory, local, or other official authorities when necessary to protect the rights of third parties or safeguard assets.
Additionally, we may share Personal Data with potential investors, buyers, lenders, or other entities within our corporate group in connection with business transactions—including asset transfers, sales, mergers, consolidations, restructuring, or bankruptcy proceedings involving the Company or any affiliated business.
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 that are stored on your device each time you visit or access our website. We use cookies to gather information about your preferences and browsing habits so we can improve your user experience, remember your preferences, 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 expire when you close your browser. Other cookies are persistent, meaning 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 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 essential
Scope
These cookies are essential for accessing the features you've requested and navigating 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 through 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. They're automatically deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognize you on each visit 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 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, which helps us enhance your experience and understand how visitors interact with our site.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are removed when you close your browser, while others remain indefinitely.
Cookies are blocked, or removed
To block or remove cookies, you'll need to adjust your browser 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 may not function 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 fulfill the purposes outlined in this Policy, or for longer periods as required by applicable law, regulations, and court orders.
We'll share your information with third-party trading platforms for an initial 12-month period. With your consent, we'll continue sharing your data for an additional 12 months.
We regularly review the personal data we maintain to confirm it's no longer required.
9. Transfers of personal information to a third-party country or to an international organization
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third-country or to international organizations). The Company takes all necessary steps to safeguard your personal data and ensure that users can exercise their rights and access effective legal recourse.
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 an adequate level of protection for Personal Data transferred 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 compliance with standard data protection clauses approved by the EU Commission under Article 46(2)(c) of the GDPR. You can view the EU Commission's approved clauses 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. Send an email to info@wealthwaydigital.uk to learn more.
10. Security of Personal Data
We have implemented appropriate organizational and technical safeguards to protect your Personal Data, including measures to prevent 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 Personal Data, including loss due to transmission errors, unauthorized third-party access, or other circumstances beyond our control. We may be required by law or other obligations beyond our control to disclose your Personal Data to third parties, such as government authorities. In such cases, we cannot control how these third parties secure your information. No data transmission over the internet is completely secure. The Company cannot ensure the security of Personal Data you transmit to us through the internet.
11. Hyperlinks to Third-Party Websites
Links to third-party websites and applications are available on our platform. These external sites and apps operate independently and are not under our control. We are not responsible for how these third parties collect or process your personal data. This privacy policy does not apply to their practices or services.
Before accessing or using any third-party website or app, we recommend reviewing their privacy policy. Please exercise caution when sharing your personal information with external services.
12. Policy Changes
When you visit any third-party websites or apps that we recommend, please review their privacy policies before deciding to access or use them. We also suggest that you carefully 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 your Personal Data, rectify any inaccuracies, and delete all Personal Data that we are not required to retain. You may also restrict the types of processing we perform on your 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 regarding 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 may access your Personal Data.
The Company will provide an electronic copy of your Personal Data currently being processed at no charge. Additional copies may incur a reasonable fee. The 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 the request would be detrimental to another person's rights or freedoms, the Company may refuse the request or limit its response.
Right to rectification
You are entitled to have inaccurate or incomplete Personal Data 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 for which they were collected; (b) You withdraw consent and there is no other legal basis for processing; (c) You object at any time, for reasons specific to your situation, to processing based on legitimate interests pursued by us or a third party; (e) Personal Data are processed unlawfully; or (f) 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 request that the Company 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 consent or a contract to which you are a party, you have the right to review your Personal Data provided to the Company.
You may request that your Personal Data be transferred directly from the Company to another controller, if technically feasible. Exercising your right to data portability does not affect your right to erasure. Data portability does not interfere with 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 profiling based solely on these legitimate interests. If we can establish compelling legitimate grounds for processing, we may continue unless you demonstrate that your rights, freedoms, or interests outweigh ours, or the processing is 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 will not affect the lawfulness of processing based on your consent prior to withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may appeal to 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 Personal Data as detailed in this section.
We will provide the information you request pursuant to these rights within one month of receiving your request. This timeframe may be extended up to two months if necessary, depending on the nature and volume of your request. We will notify you of any extension and the reasons within one month of receipt.
Unless contrary to applicable law, the information you request will be provided at no cost. 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 your identity.