Privacy Policy
Last update: 29.06.2026
We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website Hordom Markholm (the "Website").
We uphold the following principles:
To be transparent about how we collect and process your personal data:
We want you to be able to make informed choices about how Personal Data is used and processed. This is why we created our website: to give you clear, relevant information about the use of Personal Data through a range of methods and procedures.
Where we believe you need specific details, we will provide them at the appropriate time.
We are glad to answer your questions and offer any clarification you require, subject to any limitations imposed by law. You can reach us by email at the address below: info@hordommarkholm.com
Personal Data will only be used for the purposes set out in this Policy.
We may process Personal Data for several purposes: to provide the website to you and connect you with third-party trading platforms (the 'Services'), to improve the site, to protect our rights and interests, to support the maintenance and provision of the Services, to meet regulatory or legal obligations, and to carry out administrative and business activities that support the delivery and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To exercise key tools that protect your rights regarding Personal Data:
We have substantial resources in place to support the exercise of your rights. Contact us at any time to request access to your personal data. We can modify or delete it, stop using it for specific or general purposes, or transfer the information to you or to a third party. We will accommodate your requests.
Secure your Personal Data:
While we cannot guarantee complete security of your Personal Data, we are committed to applying a range of methods and techniques to keep it protected.
This concludes our Privacy and Security Policy.
1. The Scope?
This Policy describes the types of Personal Data the Company collects from natural persons and how it processes that data, shares it with third parties, secures its processes, and more.
This Policy concerns information relating 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 hold or can access.
In this Policy, "processing" means any operation that involves the use or collection of Personal Data, including its management, structuring, and storage.
Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18, and we do not knowingly allow such persons to use our services. If we learn that we hold information about a child, we will erase it as quickly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels or visit our website, we collect Personal Data. In some cases, we request your Personal Data directly. In others, we collect it by analysing how you use our Services and service channels, or by receiving information from our third-party partners.
3. There is no obligation to provide your personal information to the company, but there are consequences for withholding it.
You are not obliged to provide Us with any Personal Data. In certain circumstances, withholding this Personal Data may prevent Us from offering the Services or prevent you from accessing the website.
4. What Personal Data do We collect? When you visit our website, we collect the following personal information:
This includes your online activity log, traffic data (including IP address, date of access, and time of access), the language you used, software crash logs, the type of browser used, and information about the device you utilized. This information is not private 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's online trading platform through Us.
Personal data you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
The Company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use your Personal Data. 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 personal data to serve a legitimate interest. For example, to improve Our Services or to defend legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us by email for more details on the processing necessary to safeguard our legitimate interests.
Below are the reasons and legal grounds on which we may use the information you provide. Personal Data.
Scope
Legal Basis
To share your personal information with third parties at your request in order to access digital trading
If you request it, 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 purposes.
2. To respond to your requests, questions, or concerns
Personal Data helps us answer any questions you may have about the Services.
The legitimate interests of the Company or a third party require processing.
To meet any legal obligation, Personal Data is processed to satisfy applicable administrative, judicial, or legal requirements.
Processing is necessary to meet our legal obligations.
4. To improve Our Services
We may use Personal Data to improve Our Services. This includes crash and malfunction reports we collect in relation to the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Where processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities required to deliver Our Services
These include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar operations.
Processing is necessary for the legitimate interests of the Company or a third party.
7. To conduct analysis, including statistical analysis
We apply a range of analytical techniques, including statistical ones, to make decisions across various matters.
Where processing is necessary for the legitimate interests of the Company or a third party.
8. To protect the assets, rights, and interests of ourselves and any third party
We may process Personal Data to establish and defend legal claims, and to protect our rights, interests, and assets, or those of a third party, in accordance with any applicable laws, regulations, agreements, terms, conditions, or policies.
Processing is necessary for the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
We may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and analysis of user experiences.
You can also ask us to share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you give us to those third-party trading platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This provides the Company with the resources needed to enhance and improve the products and services it offers its customers.
Where necessary to safeguard the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, where such a 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
We may use third-party services, such as advertising partners or analytics companies, and these companies may also use cookies or similar technology.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your user experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are temporarily downloaded to your device and last only until you close your browser. Others are persistent cookies, which remain on your device for a period after you close your browser. They help the Website recognize you as a returning user and make it easier to come back.
Types of Cookies:
They may be used by us according to their purpose:
The type of cookie
These cookies are strictly necessary.
Scope
These cookies are necessary to access the features you have requested and to navigate our website. They deliver the information, products and services you have asked us to provide.
They also enable your device to download and stream data, allowing you to move around the website, use its features, and return to pages you have previously visited.
Additional Information
Cookies collect personal data such as your username and last login date to confirm that you are logged in to the site. These are deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to 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 are logged in to the site. They are erased once you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data on the site's performance and to help improve it. They also allow us to analyse how our website is used.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable person. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you will 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
If this happens, however, be aware that some or all of the Website's functions and features may not work as you expect.
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 described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to confirm it is still needed.
9. Transfers of personal data to a third-party country or to an international organisation
Your personal data may be transferred to other countries — that is, to a third country other than the one in which you reside — or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that users can assert their rights and access effective legal recourse.
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 an adequate level of protection for Personal Data, 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 under a legally binding and enforceable agreement between public bodies or authorities, pursuant to Article 46(2)(a).
- The transfer was carried out in compliance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses 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.
For details on the security measures we use to protect your Personal Data transferred to third-party countries or international organisations, contact us at info@wealthwaydigital.uk.
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held responsible 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, unauthorised access by a third party, or any other cause beyond our control.
Where legal or other obligations beyond our control require it, we may be compelled to provide your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the internet in a completely secure way. The Company cannot ensure the security of any Personal Data you send to Us via the internet.
11. Hyperlinks to third party websites
The website contains 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 them, and this Policy does not apply to any actions taken through such sites or apps.
Before accessing or using any third-party website or app, we recommend that you read their privacy policies and exercise caution before providing any Personal Data to them.
12. Changes to This Policy
Before visiting any third-party website or app, we recommend reading their privacy policies before deciding to access or use them. We also advise caution before providing any Personal Data to them.
13. Your rights regarding your personal information
You have the right to ask us to verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we no longer need. You may also restrict the scope and types of processing applied to your personal information.
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. To exercise them, write an email to the address below.
Access rights
The Company can verify the accuracy of the Personal Data being processed about you. Where such data exists, you may access it.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. If you request it, the data will be made available electronically.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request adversely affects the rights and freedoms of another person, the Company may refuse to comply or limit the extent to which it does so.
Right to rectification
The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right to Erasure
The following grounds apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to meet a legal obligation of the Company.
This right does not apply where processing is necessary (a) to fulfil a legal obligation required 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 restrict the processing of it.
Where you request that Personal Data be restricted, the data may only be retained with your consent, or to establish, exercise, or defend legal rights, or to protect 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
Where processing is carried out by automated means and is based on consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You have the right to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising the right to data portability does not affect your rights under the right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You have the right at any time to object to the use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based on those legitimate interests. If we can demonstrate compelling legitimate grounds for the processing, we may continue only where those grounds override your rights,