Privacy Policy
Last update: 13.04.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website Ledgerholm (the "Website").
We are guided by the following principles:
To be clear about how we collect and process your personal information:
We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we have created this website. To support this, we use a range of methods and procedures to give you clear, relevant information about the use of Personal Data.
Where we believe you need more specific information, we will provide it at the appropriate time.
If you have any questions, we will be pleased to help and provide any clarification you may need, subject to any legal restrictions. You can contact us by email at: info@ledgerholm.app
Personal Data will only be used for the purposes set out in this Policy.
We may process Personal Data for a variety of purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, complying with applicable legal and regulatory requirements, and carrying out administrative and business operations necessary for the provision and use of the Services.
We also process Personal Data to gain a better understanding of your preferences and needs.
To exercise important rights relating to your Personal Data:
To help you exercise your rights, we have dedicated resources in place. Please contact us at any time to request access to your Personal Data. We can amend or delete it, restrict its use for specific or broader purposes, and transfer it to you or to a third party. We will do our best to accommodate your request.
Secure your Personal Data:
Although we cannot guarantee the absolute security of your Personal Data, we are committed to using a range of measures and practices to help keep it protected.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy explains what types of Personal Data the Company collects about individuals, how it processes that data, when it may share it with third parties, and the measures it takes to keep it secure.
This Policy applies to information relating to an identified or identifiable individual. An identifiable individual is someone who can be identified directly, or indirectly through additional information we hold or can reasonably access.
In this Policy, "processing" means any activity involving the use or collection of Personal Data. This includes handling, organising and storing Personal Data.
Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect information from anyone under 18 or permit them to use our services. If we become aware that we hold information about a child, we will delete it as soon as reasonably possible.
2. What personal Data Do We Have on You?
When you use our services or channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide your Personal Data directly. In others, we collect it by monitoring and assessing how our services or channels are used, or by receiving your information from trusted third-party partners.
3. You are not required to provide the company with personal information, nor are there any consequences for choosing not to do so.
However, you are not required to provide us with any personal data. In some cases, though, choosing not to do so may prevent us from providing the Services or may limit users' access to the website.
4. What Personal Data may we collect? When you visit our website, we may collect the following personal information:
This includes details of your online activity log, traffic data (including your IP address, the date and time of access), the language used, software crash reports, the type of browser used, and information about the device you used. The information collected does not constitute 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 directly to third-party platforms to enable trading: this may include your full name, address, telephone number, and email address.
5. Legal basis and reasons for processing personal data
Your Personal Data is processed by the Company for the purposes set out in this section and on the relevant 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 as follows:
- You have consented to the processing of your Personal Data for one or more purposes. This applies where you submit personal information through the Website so that we can pass it on to a third-party trading platform.
- The Company or a third party may need to process data where this is necessary to pursue legitimate interests, such as improving Our Services or establishing, exercising, or defending legal claims.
- Processing must meet an obligation of law.
Please contact us by email if you would like further information about the processing required to protect legitimate interests.
Below, you will find a list of the reasons and legal bases on which we may use the Personal Data you provide to us.
Scope
Legal Basis
1. To share your personal information with third parties at your request in order to give you access to digital trading
If you request this, we may ask you to provide Personal Data so that we can pass it on 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, queries or concerns
We need Personal Data to address any questions you may have about the Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
3. To comply with any legal, administrative or judicial obligation, Personal Data is processed where necessary to meet applicable legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services
We may use Personal Data to improve Our Services, including any reports we receive about crashes or other issues affecting the Services.
Processing is necessary in pursuit of the Company’s legitimate interests or those of a third party.
5. To stop fraud and misuse of Our Services
Processing is necessary for the legitimate interests of the Company or those of a third party.
6. To carry out and manage activities required for the proper delivery of Our Services
This includes back-office operations, business development, strategic decision-making, oversight and similar functions.
Processing is necessary for the Company’s legitimate interests or those of a third party.
7. To carry out analysis, including statistical analysis
We use a range of analytical techniques, including statistical methods, to inform decisions on various matters.
Processing is necessary to pursue the Company's legitimate interests or those of a third party.
8. To protect our assets, rights and interests, as well as those of third parties, we may process Personal Data in order to establish, exercise or defend legal claims.
We may also process Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with any applicable laws, regulations, agreements, and relevant terms, conditions or policies.
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
6. Transfer of Personal Data to Third Party
The Company may also share Personal Data with third-party service providers that support our operations, such as hosting and storage providers, providers of IP address-related services, and user experience analytics providers.
You may also ask us to share specific Personal Data relating to you with third-party trading platforms. In such cases, we will share the Personal Data you have provided to us with those third-party trading platforms. Any use of your Personal Data by those platforms will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may share Personal Data with affiliated entities or business partners where this helps us develop, improve, and deliver our products and services more effectively.
Where necessary to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to relevant regulatory, local, or other official authorities.
We may also share your Personal Data with prospective investors, purchasers, or lenders to the Company or to any other company within the group, in connection with the same transaction (including any transfer or sale of assets of the Company or any other group company), or as part of any merger, restructuring, reorganisation, or insolvency process involving the Company or any other group business.
7. Cookies and services from third parties
We may use third-party services, including advertising providers on our website and analytics companies. These companies may also use cookies and similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They are used to collect information about your preferences and browsing behaviour in order to improve your user experience, remember your settings, and tailor the products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporarily stored on your device and remain there only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period after you close your browser. They are used to help the website 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 based on their purpose:
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for accessing the features you have requested and for moving around our website. They help us deliver the information, products and services you have asked for.
They are also needed to allow your device to download and stream data. This enables you to browse the website, use its features, and return to pages you have visited before.
Additional Information
Cookies collect Personal Data such as your username and the date of your last login, so we can confirm that you are signed in to the site. These cookies are deleted when you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognise you each time you visit our site and remember your preferences.
Additional Information
Cookies collect Personal Data, including your username and the date of your last login, to confirm that you are signed in to the site. These are deleted when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical information about the site's performance and help improve it. They also enable Us to analyse activity on our website.
Additional Information
Cookies may store anonymous data that cannot be linked to an identified or identifiable individual. Some are deleted when you close your browser, while others remain in place indefinitely.
Cookies are blocked or have been deleted
To allow or remove cookies, you'll need to change your browser settings. Below, you'll find links to guidance for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that if this happens, some or all features and functions of the Website may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. How long we keep your personal data
The Company will keep your Personal Data only for as long as needed to fulfil the purposes for which it is processed, as set out in this Policy, or for longer where permitted by applicable law, regulation, policy, or order.
We will 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 review the Personal Data we hold on a regular basis to make sure it is no longer retained than necessary.
9. Transfers of personal information to third countries or international organisations
Your personal information may be transferred to other countries, which means your personal data may be sent to a country other than the one in which you live or to an international organisation. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that individuals can exercise their rights and have access to effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or an international organisation that the European Commission has determined ensures an adequate level of protection for the Personal Data transferred to it, 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 carried out under a legally binding and enforceable agreement between public bodies or authorities within the meaning of Article 46(2)(a).
- The transfer was carried out using standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view the European 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 of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Please email info@wealthwaydigital.uk for further information.
10. Security of Personal Data
We have put in place appropriate organisational and technical measures to protect Personal Data. These measures include safeguards against the accidental or unlawful destruction, loss or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will always be maintained without interruption or error. Nor can we accept liability for any indirect, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other circumstances beyond our reasonable control.
Where required by law or due to other circumstances beyond our control, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we are unable to control how those third parties protect your Personal Data.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Hyperlinks to websites belonging to third party websites
The website may include links to third-party websites and applications. These websites and applications are not controlled or overseen by the Company. We are not responsible for how these websites or applications collect or process Personal Data, and this Policy does not apply to any actions taken through them.
If you choose to visit any third-party website or application, we recommend that you read its privacy policy before accessing or using it. We also advise you to consider carefully before providing any Personal Data.
12. Modifications to this Policy
Before visiting any third-party website or using any third-party app, we recommend that you read their privacy policies and terms carefully, and only share any Personal Data once you have decided to use their services.
13. Your rights with respect to your personal information
You have the right to ask us to confirm whether we hold Personal Data about you, to ensure that it is accurate, to correct any errors, and to delete any Personal Data we no longer need. You may also ask us to restrict certain types of processing of your personal information.
If you are resident in the EEA, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, you may contact us by email at the address below.
Access rights
The Company can confirm whether your Personal Data is being processed. If it is, you are entitled to access your Personal Data.
The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for any additional copies. Where requested, the information will be supplied in electronic form.
The right of access to Personal Data must not adversely affect the rights and freedoms of others. If complying with a request would prejudice the rights and freedoms of another person, the Company may refuse the request or limit the extent to which it is fulfilled.
Right to rectification
The Company will correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right to erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data concerning you where that processing is based on legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased in order to comply with a legal obligation to which the Company is subject.
This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under applicable law; or (b) for the establishment, exercise or defence of legal claims.
Restrictions on processing
If you dispute the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing has been restricted, the Personal Data may only be stored unless you consent to further processing, or unless such processing is necessary for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural person, or for reasons of substantial public interest.
Right to data portability
Where processing is carried out by automated means and is based on your 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 and to review it.
You are also entitled to request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights and freedoms of others.
Right to object
You have the right at any time to object to the processing of Personal Data concerning you where such processing is based on the legitimate interests pursued by the Company or by a third party. This includes profiling to the extent that it is based on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or where processing is required for the establishment, exercise or defence of legal claims, we may continue to process your Personal Data.
In relation to direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your consent was withdrawn.
You are entitled to lodge a complaint with a supervisory authority.
You may submit a complaint to a supervisory authority established to protect individuals' fundamental rights in relation to the processing of Personal Data.
Applicable law may limit your rights in relation to your Personal Data, as set out in this section 13.
We will provide the information you request under the rights set out in section 13 of this agreement within one month of receiving your request. That period may be extended by up to two further months where necessary, taking into account the complexity of the request and the number of requests received. If we extend this period, we will inform you within one month of receiving your request and explain the reasons for the delay.
Unless otherwise permitted under section 13 or applicable law, the information you request when exercising your rights under section 13 will be provided free of charge. However, if a request is manifestly unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the action requested. We may also refuse to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information to confirm that person's identity.