Rookholm

Privacy Policy

Last update: 09.03.2026

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 Rookholm (the "Website").
We uphold the following principles:

To be transparent about how we process and collect your personal information:

We want to help you make informed decisions about how your Personal Data is used and processed. That's why we've created this website. We use a range of methods and procedures to keep you informed about Personal Data usage.
Where we believe you need specific information, we'll provide it at the appropriate time.
We're happy to answer any questions and offer clarifications about any legal limitations affecting your data. Please contact us by email at: info@rookholm.com

Your personal data will only be used for the purposes outlined in this Policy.

Personal Data may be processed by us for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing site functionality, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and conducting administrative and business activities. We also process your Personal Data to better understand your preferences and needs.

To make use of important tools to protect your rights regarding Personal Data:

To help you exercise your rights, we have comprehensive resources available. Please contact us at any time to request access to your personal data. We can modify or delete it, cease using it for specific or general purposes, or transfer the information to you or a third party. We're committed to accommodating your requests.

Protect Your Personal Data:

Whilst we cannot guarantee absolute security of your Personal Data, we remain committed to employing a range of methods and techniques to safeguard it.
Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of personal data we collect about individuals and how we process, share, and secure that information. This policy concerns information relating to an identified or identifiable natural person. An identifiable individual is someone who can be directly identified or recognised through a combination of information we hold or can access. We define "processing" as any activity involving the use or collection of personal data, including its management, organisation, 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 anyone younger than 18 or permit such individuals to use our services. Should we become aware of any personal data relating to a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you access our service, channels, or website, we collect personal data. We may ask you to provide personal data directly, or we may gather it by analysing your use of our services and channels, or by receiving information from our third-party partners.

3. There is no requirement to disclose personal information to the company, and this carries no adverse consequences.

However, you're not required to provide us with any personal data. In certain circumstances, you may choose not to supply us with any personal data. This could prevent us from delivering the Services or prevent users from accessing the website.

4. What personal data do we collect? When you visit our website, we gather the following information about you:

This includes information about your online activity log, traffic data (including your IP address, access date, access time, and language preference), software crash logs, browser type, and device information. The information collected is not personally identifiable and cannot be used to identify you.
Personal Data We Receive From You: any personal data you provide at your own discretion when you connect with a third-party online trading platform through us.
Personal information you provide directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.

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 valid legal basis. The legal grounds upon 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 when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
  • We or a third party may need to process your information to pursue our legitimate interests. For example, this might include improving our services or defending legal claims.
  • Processing must comply with legal requirements.

Contact us via email for further details about the processing required to protect our legitimate interests.
Below is a list of the reasons and legal grounds we may use to process your personal data.

Scope

Legal Basis

To share your personal information with third parties at your request for access to digital trading services
If you request it, we may ask you to provide Personal Data that we can forward to third-party companies.

You have consented to the processing of your personal data for one or more of the specified reasons.

2. To address your requests, questions or concerns
We need your Personal Data to help us respond to any enquiries you may have about our Services.

We need to process personal data to protect the legitimate interests of the Company or a third party.

3. To meet legal obligations -- Personal Data is processed to fulfil any administrative, judicial or legal requirements.

To meet legal requirements, this processing step is necessary.

4. To enhance Our Services Personal
Data may be used by us to improve Our Services. This includes, amongst other things, crash reports and malfunction data collected in relation to the Services.

We need to process your data to protect the legitimate interests of the Company or a third party.

5. To prevent fraud and misuse of our services

We need to process personal data to protect the legitimate interests of the Company or a third party.

6. To perform and manage actions that align with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, and oversight mechanisms.

We need to process personal data to pursue 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 across different areas.

We need to process your personal data to protect the legitimate interests of the Company or a third party.

8. To protect our assets, rights and interests, as well as those of third parties, we have developed HTML0 to establish and defend legal claims
We may process your Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with all applicable laws, regulations, agreements, terms, conditions and policies.

We need to process personal data to protect the legitimate interests of the Company or a third party.

6. Transfer of Personal Data to Third Parties

The Company may share your Personal Data with third-party service providers, such as hosting and storage providers, as well as IP address information and user experience analytics.
You may also request that we share your Personal Data with third-party trading platforms. We will disclose your Personal Data to these trading platforms in accordance with their respective 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 enhance and improve the products and services we offer our customers.
Where necessary to protect the rights of third parties or our assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may additionally share your Personal Data with potential investors, buyers, or lenders to the Company or entities within our group in connection with any transaction (including the transfer or sale of Company assets or group company assets) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or other group entities.

7. Third-party cookies and services

Third-party services, such as advertising and analytics providers, may be used 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 our website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your preferences, and personalise the products and services we offer. Cookies are also used for statistical and analytical purposes.
Some cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Other cookies are persistent and remain on your device for a set period after you close your browser. Persistent cookies help us recognise you as a returning visitor and allow you to return to the website more seamlessly.

Types of Cookies:

They may be used by us for 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, enabling you to navigate the website, use its features, and return to previously visited pages.

Additional Information

Cookies collect personal data, such as your username and last login date, to confirm that you're logged into the site. They're automatically erased when you close your web browser (session cookies).

The type of cookie

Functionality Cookies

Scope

Cookies allow us to recognise you when 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 that 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 gather statistical data about site performance and to help us enhance your experience. They also enable us to analyse how our website is being used.

Additional Information

Cookies store anonymous data that is not linked to any identifiable person. Some cookies are removed when you close your browser, whilst others remain 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's functionality may not work 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, as described 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 remains necessary.

9. Transfers of personal information to third-party countries or international organisations

Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third-country or to international organisations). The Company takes all necessary steps to safeguard the personal data you provide and ensure that data users have the ability to 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 personal data protection 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 made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
  • The transfer was completed in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission 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.

The Company can provide information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please email us at info@wealthwaydigital.uk

10. Security of Personal Data

We have implemented appropriate organisational and technical measures to protect your Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without errors. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of your Personal Data, including (but not limited to) unauthorised access by third parties, transmission errors, or causes beyond our reasonable control.
Where required by law or other obligations beyond our control, we may be compelled to disclose your Personal Data to third parties, such as public authorities. We cannot control the security measures applied to your Personal Data by such third parties in these circumstances.
Data transmitted over the internet cannot be guaranteed as completely secure. The Company cannot ensure the security of 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 that operate independently of the Company. We are not responsible for how these third-party websites or apps collect or process your personal data. This privacy policy does not apply to activities conducted through such external sites or applications.
Before accessing or using any third-party websites or apps, we recommend that you review their privacy policies carefully. We also advise you to exercise caution when providing any personal data to them.

12. Changes to this Policy

When visiting any third-party websites or apps that we recommend, please read their privacy policies before deciding whether to access or use them. We also suggest reviewing what Personal Data you choose to share with them.

13. Your rights regarding your personal information

You are entitled to request that we verify the accuracy of Personal Data being collected about you, rectify any inaccuracies, and delete all Personal Data that we no longer require. You may also restrict the scope and types of Personal Data processing.
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. You may exercise your rights by sending an email to the address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. If accurate, you are able to access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be made available electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to another person's rights and freedoms, the Company may refuse to comply with the request or limit its ability to fulfil it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete or inaccurate Personal Data concerning you be corrected, taking into account the reason for processing.
Right to erasure
The following circumstances apply: (a) Personal Data are no longer necessary 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, for reasons specific to your situation, to the processing of Personal Data based on legitimate interests pursued by us or a third party; (d) Personal Data are being processed unlawfully; or (e) Personal Data must be deleted to comply with a legal obligation.
This right does not apply where processing is necessary (a) to fulfil a legal obligation under European Union or Member State law; or (b) to establish, exercise or defend legal rights.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing.
If you request that Personal Data be restricted, it may only be retained with your consent or to establish, exercise or defend legal rights, or to protect the rights of another individual, or where there is a significant 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 a contract to which you are a party, you have the right to request and review your Personal Data 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 right to erasure is not affected by exercising your right to data portability. The right to transfer data does not interfere with the rights or freedoms of others.
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 your Personal Data, we will not be able to continue processing unless we can demonstrate that they outweigh your rights, freedoms or interests, or the establishment, exercise or defence of legal rights.
Regarding 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 for us to process Personal Data about you at any time. This will not affect the lawfulness of any processing that was based on your consent before it was withdrawn.
You are entitled to lodge a complaint with the supervisory authority in your jurisdiction.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to Personal Data processing within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as set out in this section 13.
We will provide you with the information you request in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons.
Unless otherwise provided for in section 13, the information you request pursuant to your rights under section 13 will be provided free of charge. If your request is manifestly unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover our administrative costs or may decline to act.
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