Privacy Policy
Last update: 12.07.2026
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 Kestrel Fundholm (the "Website").
We are guided by the following principles:
To ensure full transparency about how your personal information is collected and processed:
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 and relevant information about the use of Personal Data.
Where we believe you need more specific details, we will provide them at the appropriate time.
We are happy to answer any questions you may have and to provide any clarification you need in relation to any legal limitations. You can contact us by email at the address below: info@kestrelfundholm.com
Personal Data will only be used for the purposes set out in this Policy.
We may process Personal Data for a number of purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, safeguarding our rights and interests, supporting the maintenance and delivery of the Services, complying with applicable legal or regulatory requirements, and carrying out administrative and business operations necessary for the provision and use of the Services.
We also process Personal Data to better understand your preferences and requirements.
To use important tools that help protect your rights in relation to Personal Data:
To help you exercise your rights, we have dedicated resources in place. Contact Us at any time to request access to your Personal Data. We can update or delete it, stop processing it for specific purposes or more generally, and transfer the information to you or to a third party. We will do our best to accommodate your request.
Protect your personal data:
Although we cannot guarantee the absolute security of your Personal Data, we remain committed to using a range of measures and safeguards to help keep your Personal Data 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 that data is processed, when it may be shared with third parties, and the measures taken to keep it secure.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including by reference to additional information that we hold or can reasonably access.
In this Policy, "processing" means any operation involving the use or collection of Personal Data. This includes the organisation, structuring, management, and storage of Personal Data.
Our services are intended for a general audience and are not designed for anyone under 18 years of age. We do not knowingly collect information from, or permit the use of our services by, anyone under the age of 18. If we become aware that we hold information relating to a child, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About 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 other cases, we collect your Personal Data by monitoring how our services or channels are used, or by receiving your information from our third-party partners.
3. You are not required to provide the company with personal information, and there are no consequences for choosing not to do so.
However, you are not required to provide Us with any Personal Data. In some cases, if you choose not to do so, We may be unable to provide the Services or users may be unable to access the website.
4. What Personal Data do we collect? When you visit our website, we may collect the following personal information:
This includes details from 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 includes 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 legal basis that applies in each case.
If there is no valid legal basis, the Company cannot process your Personal Data. 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 provide 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 is necessary to comply with a legal obligation.
Please contact us by email if you would like further details about any processing carried out to protect legitimate interests.
Below is a summary 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 access digital trading
If you request this, we may ask you for Personal Data so that it can be passed 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 require Personal Data so we can 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. Personal Data is processed to comply with any legal, administrative or judicial obligation, and to meet applicable legal requirements.
Processing is necessary to meet legal requirements.
4. To improve Our Services
We may use Personal Data to improve Our Services. This includes, among other things, crash reports and reports of any faults or issues we collect in connection with the Services.
The Company’s legitimate interests, or those of a third party, must be processed.
5. To help prevent fraud and misuse of our Services
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required for the delivery of Our Services
This includes back-office operations, business development, strategic decision-making, oversight procedures and related functions.
Processing is necessary to support 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 methods, including statistical techniques, to support decision-making on various matters.
Processing is necessary for 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 where necessary 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 applicable laws, regulations, agreements, and any relevant terms, conditions or policies.
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. Disclosure of Personal Data to Third Parties
The Company may also share Personal Data with third-party service providers that support our operations, such as hosting and storage providers, IP address data providers, and providers of user experience analytics.
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. Their use of your Personal Data 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 is necessary to provide the resources required to improve and develop the products and services we offer to our customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other public 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 a similar transaction, including any transfer or sale of assets of the Company or another group company, or as part of any merger, restructuring, consolidation, or insolvency process involving the Company or any other business within the group.
7. Cookies and third-party services
We may use third-party services, including providers that display advertising on our website and analytics partners. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or use the website. They help us collect information about your preferences and browsing activity so we can improve your user experience, remember your settings, and tailor 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 temporary and are downloaded to your device for the duration of your visit, then removed when you close your browser. Other cookies are persistent cookies. These remain on your device for a period of time after your browser is closed. They help the Website recognise you when you return and make it easier for you to access the website again.
Types of Cookies:
We may use them depending on their purpose:
Cookie type
Cookies are essential for this site to function properly
Scope
These cookies are essential to give you access to the features you have requested and to help you move around our website. We use them to provide the information, products and services you have asked for.
They are also needed so your device can download and stream data. This allows you to browse the website, use its features, and return to pages you have visited before.
Additional Information
Cookies may collect Personal Data, including your username and the date of your last login, to confirm that you are signed in to the site. These session Cookies are deleted when you close your web browser.
Cookie type
Functionality Cookies
Scope
Cookies help us recognise you each time you visit our site and remember your preferences.
Additional Information
Cookies may collect Personal Data, including your username and the date of your most recent login, to confirm that you are signed in to the site. These are deleted once you close your web browser (session Cookies).
Cookie type
Cookies for performance
Scope
Cookies are used to collect statistical information about how the site performs and to help improve it. They also allow Us to analyse activity on our website.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable natural person. They can be deleted when you close your browser, while other cookies remain valid for an indefinite period.
Cookies are blocked or have been deleted
To allow or manage cookies, you'll need to change your browser settings. Below, you'll find links to guidance for some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some, or even all, functions and features of the Website may not work as expected if this happens.
ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. Retention of your personal data
The Company will keep your Personal Data for as long as necessary to carry out the purposes for which it is processed, as set out in this Policy, or for longer where permitted under applicable law, regulation, policy, or legal requirement.
We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue to share 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 a third country or to an international organisation
Your personal information may be transferred to other countries, which means your personal data may be sent to a country other than the one where you live or to an international organisation. The Company takes all necessary steps to protect the Personal Data you provide and to ensure that data subjects can exercise their rights and have access to effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for Personal Data transferred to it under Article 45(3) of Regulation 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 in accordance with Article 46(2)(a).
- The transfer was carried out in line with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view these clauses on the European Commission website 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. Personal Data Security
We have put in place appropriate organisational and technical measures to protect Personal Data. These measures are designed to help prevent the accidental or unlawful destruction, loss or alteration of Personal Data.
However, we cannot guarantee that the security of your Personal Data will always be maintained without issue. Nor can we accept liability for any indirect, incidental or consequential loss arising from the use or disclosure of Personal Data. This includes, without limitation, any disclosure of Personal Data resulting from transmission errors, unauthorised access by a third party, or any other cause outside our reasonable control.
Where we are subject to legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, including public authorities. In such circumstances, we have no control over the level of security applied to your Personal Data by those third parties.
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. Links to third-party websites
The website may contain links to third-party websites and applications. These websites and applications are not controlled or supervised by the Company. We are not responsible for how these third parties collect or process Personal Data, and this Policy does not apply to any actions taken on such websites or applications.
If you visit any third-party website or application, we recommend that you read its privacy policy before choosing to access or use it. We also recommend that you consider carefully before providing any Personal Data to them.
12. Changes to this Policy
Before visiting any third-party websites or apps, we recommend that you read their privacy policies and decide whether you wish to access or use them. We also advise you to consider carefully before sharing any Personal Data with them.
13. Your rights in relation to your personal information
You have the right to ask us to confirm whether we hold Personal Data about you, to correct any inaccuracies, 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 Personal Data you provide to us. To exercise any of these rights, you can contact us by email at the address below.
Right of access
The Company can confirm whether your Personal Data is being processed. If it is, you have the right 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 provided in electronic format.
The right of access must not adversely affect the rights and freedoms of others. Where fulfilling a request would negatively affect another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can comply.
Right to rectification
The Company will correct inaccurate Personal Data. You also have the right to have incomplete Personal Data completed, taking into account the purpose of the processing.
Right to erasure
This right applies where: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object to the processing of your Personal Data, on grounds relating to your particular situation, where the processing is based on our legitimate interests or those of a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under applicable law; or (b) for the establishment, exercise or defence of legal claims.
Restrictions on processing
If you contest 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 where 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 important 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 also have the right to ask for your Personal Data to be transferred directly by 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 that 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 the processing which override your interests, rights and freedoms, or if the processing is required for the establishment, exercise or defence of legal claims, we may continue processing 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 on the basis of your consent before it was withdrawn.
You have the right to lodge a complaint with the relevant supervisory authority.
You may submit a complaint to a supervisory authority established in an EU Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
Applicable law may limit your rights in relation to your Personal Data, as described 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. This period may be extended by up to two further months where necessary, depending on the nature and number of requests. If an extension applies, 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. Where 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.