Privacy Policy
Last update: 06.05.2026
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 the information you provide through the website Irwynn Gainholm (the "Website").
These principles will be upheld:
To be clear about how we process and collect your personal information:
We want you to make informed decisions about how your Personal Data is used and processed. That's why we created this website. We use different methods to provide you with clear information about Personal Data handling.
If we think you need specific details, we'll provide them at the right time.
We're happy to answer your questions and explain anything about how the law affects your data. Contact us by email at: info@irwynn-gainholm.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 Services (which may connect you with third-party trading platforms), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting legal and regulatory requirements, and carrying out administrative and business activities. We also process your Personal Data to better understand your preferences and needs.
Personal Data are also processed by us in order to better comprehend your preferences and needs.
To exercise your rights regarding personal data protection, you can access and use important tools available to you.
To help you exercise your rights, we have substantial resources available. Contact us anytime to request information about your personal data. We can modify or delete it, stop using it for specific 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're committed to using a range of methods and techniques to keep it protected.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects from natural individuals and how it processes, shares, secures, and manages that data.
This Policy concerns 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 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 old. We do not knowingly collect information from persons younger than 18 or permit them to use our services. If we become aware of any information relating to children, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you access our services, channels, or website, we collect your Personal Data. In some cases, we ask for it directly. In others, we gather it by analysing your use of our Services and channels, or by receiving information from our third-party partners.
You don't need to disclose personal information to the company, and there are no consequences if you don't.
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. This could prevent us from delivering our services or restrict 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 browser language), software crash logs, browser type, and device information. This data is non-personal 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 includes your full name, address, phone number, and email address to facilitate trading.
5. Legal Basis and Reasons for Processing Personal Data
Your Personal Data is processed by the company for the purposes outlined in this section, in accordance with the applicable legal basis.
The company cannot process your Personal Data without a legal basis. The legal grounds on which the company may process your Personal Data are:
- You've consented to the processing of your Personal Data for one or more reasons. 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 data to serve their legitimate interests. For example, this includes improving Our Services or defending against legal claims.
- Processing must comply with legal requirements.
Contact us by email for more details about how we process your information to protect our legitimate interests.
Below is a list of the reasons and legal grounds we may use your personal data for.
Scope
Legal Basis
We may request your personal information to share with third-party companies if you ask us to, in order to help you gain access to digital trading services.
You've consented to us processing your Personal Data for one or more of these reasons.
2. To address your requests, questions or concerns
Personal Data is necessary to help us respond to any enquiries you may have about the Services.
The Company or a third party's legitimate interests require the processing of this information.
3. To comply with legal obligations, we process Personal Data as required by law and administrative, judicial, or legal proceedings.
To comply with legal requirements, processing is necessary.
4. To enhance Our Services
We may use your Personal Data to improve Our Services, including crash reports and malfunction information we collect relating to the Services.
We need to process personal data to pursue 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 that requires processing of this data.
6. To perform and manage activities that align with the requirements of Our Services
This includes back-office functions, business development, strategic decision-making, oversight, and related operations.
We need to process personal data 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.
We need to process personal data to protect the legitimate interests of the Company or a third party.
To protect our assets, rights, and interests—as well as those of third parties—we may process Personal Data to establish and defend legal claims in accordance with applicable laws, regulations, agreements, and our terms and policies.
We need to process data to protect the legitimate interests of the Company or a third party.
6. Transferring Your 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 use IP address information and user experience analytics.
You can request that we share specific Personal Data about you with third-party trading platforms. When you do, we'll provide your Personal Data to these 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 help us enhance and improve our products and services.
If necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may share Personal Data about you with potential investors, buyers, lenders to the Company, or other group companies in connection with any transaction (including asset transfers or sale of the Company or group companies) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any group company.
7. Third-party cookies and services
Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also use cookies or other tracking technology.
Cookies are small text files placed on your device each time you visit our website. We use cookies to understand your preferences and browsing habits, improve your experience, remember your settings, and personalise the products and services we offer. Cookies also help us gather statistics and analytics data.
We use two main types of cookies. Session cookies are temporary and are deleted when you close your browser. Persistent cookies remain on your device after you close your browser and help us recognise you as a returning visitor, allowing you to pick up where you left off.
Types of Cookies:
We may use them based on their intended purpose:
The type of cookie
Cookies are essential
Scope
These cookies are essential for accessing the features you've requested and navigating 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 move around 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 allow us to recognise you each time you visit our site and to save 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 automatically erased when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect statistical data about site performance and help improve your experience. They also allow us to analyse how our website is being used.
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 valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, 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 fulfil the purpose of processing it, as outlined in this Policy, or for longer periods as permitted by applicable law, regulations, and orders.
We'll share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer required.
9. Transferring personal information to countries outside the EU or to international organisations
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country, meaning a country outside where you reside) or to international organisations. The Company takes all necessary steps to protect your personal data and ensure that you can exercise your rights and access effective legal remedies.
These protections 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, as set out in 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 complied with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. You can view the EU Commission's adopted 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 details 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 more information.
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 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 but not limited to unauthorised access by third parties, transmission errors, or other circumstances beyond our control.
Where required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. We cannot control the security measures applied by these third parties.
No method of internet transmission is entirely secure. We cannot guarantee the security of Personal Data you send to us over the internet.
11. Links 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 are not responsible for how they collect or process your Personal Data. This Policy does not apply to activities conducted through such sites or apps.
Before accessing or using any third-party website or app, we recommend reviewing their privacy policies. We also advise you to exercise caution when sharing Personal Data with them.
12. Changes to this Policy
When visiting any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest reviewing what Personal Data you share with them.
13. Your rights regarding your personal information
You are entitled to request us to verify the accuracy of Personal Data being collected about you, to correct any inaccuracies, and to delete all Personal Data no longer required by us. You may also restrict the 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 information you provide relating to your Personal Data. You may request to exercise these rights by emailing 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 the Personal Data currently being processed and may charge a reasonable fee for additional copies. The data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request would harm another's rights and freedoms, the Company can refuse or limit compliance.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You may demand that any incomplete or inaccurate Personal Data concerning you be corrected, taking into account the processing purpose.
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 to process; (c) You object at any time, based on a reason specific to your situation, to the processing of Personal Data about yourself 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 removed to comply with a legal obligation.
This right does not apply when processing is necessary (a) to fulfil an obligation required under European Union law or Member State law; or (b) to create, 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 give consent or to create, 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 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 interfere with anyone else's rights or freedoms.
Right to object
You have the right at any time to object to any processing of Personal Data concerning you that is 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 will not continue unless you can demonstrate that they are outweighed by your rights, freedoms, or interests, or by the exercise, establishment or defence of legal rights.
Regarding direct marketing, you have the right at any time to object to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for us to process Personal Data about you at any time. This will not affect the legality of any 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 laws may limit your rights relating to Personal Data concerning you, as detailed in this section.
We will provide the requested information regarding your rights within one month of receiving your request. This timeframe may be extended to two months if necessary, depending on the nature and volume of requests. We will notify you of any extension and provide reasons within one month of receiving your request.
As long as it does not contradict this section, information requested under your rights will be provided free of charge. If the 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 doubt your identity, the Company may request further information to verify it.