Privacy Policy
Last update: 30.07.2026
We ("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 Cairn Vermoode (the "Website").
We uphold the following principles:
To explain how we collect and process your personal information:
We want you to make informed choices about the use and processing of Personal Data. This is why we created this website: to give you relevant information about how Personal Data is used, through a range of methods and procedures.
Where we believe you require specific details, we will provide these at the appropriate time.
We are happy to answer any questions you may have and will provide any clarifications you require, subject to any limitations imposed by law. You can reach us by email at the address below: info@cairnvermoode.com
We use Personal Data only for the purposes set out in this Policy.
We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the "Services"), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities related to the Services.
We also process Personal Data to better understand your preferences and needs.
To exercise meaningful controls in relation to your rights over Personal Data:
We maintain substantial resources to support the exercise of your rights. Contact us at any time to request information regarding your personal data. We will modify or delete it, or stop using it for specific or general purposes. We can also transfer the information to you or to a third party. We will accommodate your requests wherever possible.
Protect Your Personal Data
While we cannot guarantee absolute security of your Personal Data, we can guarantee that we will continue to employ a variety of methods and techniques to protect it.
Our Privacy and Security Policy is complete.
1. The Scope?
This policy explains the types of Personal Data the Company collects on natural persons, and how it processes, shares, and secures that data.
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 through additional information we hold or are able to access.
The Policy defines "processing" as any operation involving 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 collect information from any person under 18, and we do not knowingly permit such persons to use our services. If we learn that we have collected information about a child, we will delete it as quickly as possible.
2. What Personal Data Do We Hold About You?
We collect Personal Data when you access our services and channels or visit our website. In some cases, we request this information directly from you. In others, we gather it by analysing how you use our Services and service channels, or by receiving it from our third-party partners.
You are not required to disclose personal information to the company. However, doing so may be necessary for us to provide certain Services, and withholding it may prevent us from delivering our Services or granting you access to the website.
You are not obliged to provide Us with any Personal Data. However, in certain circumstances, failure to supply Personal Data may prevent Us from delivering the Services or prevent you from accessing the website.
4. What kind of Personal Data do We collect? When you visit our website, we collect the following personal information:
This includes information about your online activity log, data about your traffic (including IP address, date of access, and time of access), the language you used, software crash logs, the type of browser used, and information regarding the device you utilized. The information We collect is not personal data and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us at your own choice when you connect with an online trading platform of a third party through Us.
Personal data you provide specifically to third-party platforms to facilitate trade: this data 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 Personal Data concerning you. The legal grounds on which the Company relies to process Personal Data regarding you are set out below:
- You have consented to the processing of your Personal Data for one or more reasons, such as where you submit personal information via the Website so that we may transfer it to a third-party trading platform.
- The Company or a third party may need to process your data to meet a legitimate interest, for example, to improve Our Services or to defend legal claims.
- Processing is permitted where required to comply with a legal obligation.
Contact us by email for further details on the processing necessary to safeguard our legitimate interests.
Below is a list of reasons and legal grounds for which we may use the information you provide us with: Personal Data.
Scope
Legal Basis
To disclose your personal information to third parties at your request, to enable access to digital trading
If you request this, we may collect personal data from you in order to 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, questions or concerns
Personal Data is necessary to help us respond to any questions you may have regarding the Services.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
To comply with legal, administrative, or judicial obligations, in which case Personal Data is processed to the extent required by law.
Processing is required to comply with our legal obligations.
4. To improve Our Services
We may use Personal Data to improve Our Services. This includes any crash or malfunction reports we collect in connection with the Services.
Processing may also be necessary to protect the legitimate interests of the Company or the interests of a third party.
To prevent fraud and misuse of Our Services
Processing may be necessary to pursue the Company's legitimate interests or the interests of a third party.
To carry out and manage actions in line with the requirements of Our Services
Such activities include back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is necessary for the legitimate interests pursued by the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform decisions on different matters.
Processing is necessary for the legitimate interests of the Company or the interests of a third party.
8. To safeguard our assets, rights and interests as well as those of third parties
We process Personal Data to establish and defend legal claims, and to safeguard our rights, interests and assets, or those of third parties, in compliance with applicable laws, regulations, agreements, terms or policies.
Processing may be necessary to pursue the Company's legitimate interests or the interests of a third party.
6. Transfer of Personal Data to Third Parties
The Company 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 experience.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you have given us to those third-party trading platforms. Use of your Personal Data is then subject to their 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 customers.
Where necessary to safeguard the rights of third parties or protect assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction such as the transfer or sale of assets belonging to the Company or any other group company, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
Cookies and Third-Party Services
We may use third-party services, such as advertising providers or analytics companies, on our website. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. We use cookies to gather information about your preferences and browsing habits, improve the user experience, remember your preferences, and tailor the products and services that may interest you. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are downloaded temporarily to your device and expire shortly after you close your browser. Other cookies are persistent, remaining on your device for a period after your browser is closed. These help the website recognise you as a returning user and allow you to access the website more easily on future visits.
Types of Cookies:
We may use them for the following purposes:
Cookie type
Cookies are strictly necessary
Scope
These cookies are essential for accessing the features you have requested and for navigating our website. They are used to deliver the information, products and services you have asked us for.
Your device requires them to download and stream data, allowing you to navigate 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. They are erased once you close your web browser (session Cookies).
Cookie type
Functionality Cookies
Scope
Cookies let us recognise you each time you visit our site and remember your preferences.
Additional Information
These Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
Cookie type
Cookies for performance
Scope
We use cookies to gather statistical data on the site's performance and to help improve it. They also allow Us to carry out analysis of our website.
Additional Information
Cookies store anonymous data that cannot be linked to an identifiable person. Some are removed when you close your browser, while others remain valid indefinitely.
Cookies blocked or removed
To block or remove cookies, you will 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
If this happens, be aware that some or all of the Website's functions and features may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data
The Company will retain Personal Data about you for as long as necessary to fulfil the purpose of processing 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 sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer needed.
9. Transfers of Personal Information to a Third Country or International Organisation
Your personal data may be transferred to other countries, meaning it may be transmitted to a third country (a 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 data subjects can assert their rights and access effective legal recourse.
These protections and safeguards are accessible to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation which the EU Commission has determined provides adequate protection for Personal Data transferred to it, 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 pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer complies with the standard contractual clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
For further details on the security measures we use to protect Personal Data transferred to third-party countries or international organisations, please contact us at info@wealthwaydigital.uk
10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration. These measures are reviewed and updated as necessary to maintain an appropriate level of security. While we take reasonable steps to safeguard your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you provide your personal data at your own risk. You are responsible for keeping your account credentials, passwords, and seed phrase confidential. We recommend that you do not share this information with anyone. Loss of your seed phrase may result in permanent loss of access to your wallet and its contents, as this data is not stored or recoverable by us. Should a data breach occur that affects your personal data, we will notify you and take appropriate action in accordance with applicable law.
We have implemented appropriate organisational and technical measures to safeguard Personal Data, including measures to prevent its accidental or unlawful destruction, loss or alteration.
We cannot guarantee that your Personal Data will remain secure at all times. We accept no liability for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data, including but not limited to disclosure caused by transmission errors, unauthorised third-party access, or any other cause beyond our control.
Where required by legal or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these cases, we have no control over the security measures applied to your Personal Data by those third parties.
No transmission of Personal Data over the internet can be guaranteed completely secure. The Company cannot ensure the security of any Personal Data you transmit to us online.
11. Hyperlinks to third-party websites
The website may contain links to third-party sites and applications. These are not supervised by the Company, and We are not responsible for the collection or processing of Personal Data by such websites or apps. This Policy does not apply to actions taken through third-party sites or apps.
Before accessing or using any third-party website or app, We recommend that you review its privacy policy. We also recommend caution before providing any Personal Data to them.
12. Changes to This Policy
Before accessing or using any third-party website or app We recommend, please read its privacy policy. We also advise caution when providing Personal Data to third parties.
13. Your rights with respect to your personal information
You are entitled to request that we verify the accuracy of Personal Data collected about you, to rectify any errors, and to delete any Personal Data We are not required to retain. You may also request restriction of the scope of processing of your Personal Data.
If you reside in the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may request to exercise these rights by writing to the email address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. Where such Personal Data exists, you are entitled to access it.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another party, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of processing.
Right to erasure
The following grounds apply: (a) Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, on grounds relating to your particular situation, to processing of Personal Data based on legitimate interests pursued by Us or by a third party; (d) Personal Data have been unlawfully processed; or (e) Personal Data must be erased to comply with a legal obligation applicable to the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or the law of a Member State, or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing is restricted, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, 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 party, you have the right to review the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure remain unaffected by the exercise of your right to data portability. The right to data portability does not affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you where such processing is based on legitimate interests pursued by the Company or a third party, including profiling based solely on these legitimate interests. Where the Company can demonstrate compelling legitimate grounds for processing, We may continue to process your Personal Data unless you can demonstrate that your rights, freedoms, and interests override those grounds, or the processing is necessary for the exercise or defence of legal claims.
With regard to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to Our processing of Personal Data about you at any time. This will not affect the lawfulness of any processing carried out on the basis of consent prior to its 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 in relation to the processing of Personal Data within the European Union.
European Union and Member State law may impose limitations on your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide the information requested under the rights set out in section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, taking into account the nature of the request and the number of requests received. We will notify you of any such extension, and the reasons for it, within one month of receiving your request.
Subject to the provisions of section 13, information requested under your rights in section 13 will be provided free of charge. Where a request is unfounded or excessive, particularly where it is repetitive, We may charge a reasonable fee to cover the administrative cost of providing the information or taking the requested action, or may decline to act on the request.
Where We have reasonable doubts about the identity of the person making the request, the Company may request additional information to confirm identity.