Gem Wealthholm

Privacy Policy

Last update: 24.05.2026

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 information you provide through the website Gem Wealthholm (the "Website").
These principles will be defended:

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

We want to help you make informed decisions about how we use and process your personal data. That's why we've built this website. We use various methods to give you 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 data protection limits under the law. Contact us by email at: info@gem-wealthholm.com

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

We process your personal data for several purposes, including offering our website and Services (which connect you with third-party trading platforms), improving the site, protecting our rights and interests, maintaining and providing the Services, meeting regulatory and legal requirements, and conducting administrative and business activities to support service delivery and use. 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 use important tools that protect your rights regarding your Personal Data:

To exercise your rights, we have substantial resources available. Contact us at any time to request your personal data. We can modify or delete it, stop using it for specific or general purposes, transfer it to you or a third party, and accommodate your requests.

Secure Your Personal Data:

While we cannot guarantee absolute security of your personal data, we're committed to using a range of industry-standard methods and techniques to protect it.
Our Privacy and Security Policy provides full details.

1. The Scope?

This policy outlines the types of personal data the Company collects from individuals and how it processes, shares, secures, and manages that information.
This Policy applies to 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.
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 minors or permit them to use our services. If we become aware of any data relating to children, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our service and channels or visit our website, we collect Personal Data about you. We may ask for your Personal Data directly in some cases, or we may gather it by analysing how you use our Services and channels, or by receiving information from our third-party partners.

You're not required to share personal information with 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, if you choose not to supply personal data, we may be unable to offer our services or allow users to access the website.

4. What 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, time of access, and device type), the language you used, software crash logs, the type of browser used, and information about the device you utilised. The information we collect is not private information 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 Information You Provide 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 Your Personal Data

Your Personal Data is processed by the Company for the purposes outlined in this section and in accordance with the applicable legal basis.
The Company cannot process your Personal Data without a valid legal basis. The legal grounds the Company relies on to process your Personal Data are:

  • You've consented to us processing your personal data for one or more reasons, including 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 information to pursue their legitimate interests. For example, this includes improving our Services or defending legal claims.
  • Processing must comply with legal requirements.

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

Scope

Legal Basis

To share your personal information with third parties when you request access to digital trading
If you ask us to, we may collect Personal Data from you and pass it on to third-party companies.

You've given your consent for your Personal Data to be processed for one or more reasons.

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

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

We process your Personal Data to comply with legal, administrative, and judicial obligations.

To meet legal requirements, we need to process your information.

4. To enhance Our Services, We may use Your Personal Data to improve Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.

We need to process personal 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 in line with Our Services requirements
This includes back-office functions, business development, strategic decision-making, oversight mechanisms, and similar activities.

The Company or a third party has a legitimate interest that requires the processing of your data.

7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different matters.

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've established processes to defend our 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, and our terms and conditions.

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

6. Sharing Your Personal Data With 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 to analyse user experiences.
You can request that we share your Personal Data with third-party trading platforms. When you do, we'll provide your Personal Data to those platforms, whose use of it is governed by their own 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 the products and services we offer.
If required to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may share your Personal Data with potential investors, buyers, lenders to the Company, or other entities within our group of companies in connection with any transaction (including the transfer or sale of Company assets or assets of other group entities), merger, restructuring, consolidation, or bankruptcy involving the Company or any other business in the group.

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 other tracking technologies.
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 user experience, remember your settings, and personalise the products and services we recommend. Cookies also help us gather statistics and analytics data.
Some cookies we use are session cookies. These are temporary files downloaded to your device and deleted when you close your browser. Other cookies are persistent and remain on your device for a set period after you close your browser. We use persistent cookies to recognise you as a returning user and help you access the website more easily.

Types of Cookies:

They may be used by us according to their intended purpose:

The type of cookie

Cookies are essential

Scope

These cookies are necessary to access the features you've requested and navigate 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 help us recognise you when you visit our site and remember your preferences.

Additional Information

Cookies collect personal information like your username and last login date to keep you logged in to the site. They're automatically deleted when you close your browser (session cookies).

The type of cookie

Cookies for performance

Scope

We use cookies to collect performance data and improve your experience on our site. They also help us analyse how our website is being used.

Additional Information

Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are deleted when you close your browser, while others remain indefinitely.

Cookies are blocked, or removed
Your browser settings are preventing or removing cookies. Below are links to help you adjust your browser settings for some of the most popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

However, be aware that certain functions or the entire Website 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 outlined in this Policy, or for longer periods as permitted by applicable law, regulations, and policies.
We'll share your information with third-party trading platforms for an initial 12-month period. If you consent, we'll continue sharing your data for a further 12 months.
We regularly review retained Personal Data to confirm it's no longer required.

Transfers of personal information to third parties or international organisations

Your personal information may be transferred to other countries—for example, your personal data may be sent to a third country (a country outside where you live) or to international organisations. We take all necessary steps to protect your personal data and ensure you can exercise your rights and access effective legal remedies.
These protections apply to all residents of the EEA (European Economic Area).

  • Transfer to a third country or international organisation that the EU Commission has deemed to provide adequate protection for Personal Data, as determined under 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 data protection clauses approved by the EU Commission under Article 46(2)(c) of the GDPR. You can view the clauses approved by the EU Commission 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've implemented appropriate organisational and technical measures to protect your Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. However, we cannot guarantee that Personal Data will remain secure without errors. We're not responsible for any indirect, incidental, or consequential losses arising from the use or disclosure of Personal Data—including breaches resulting from transmission errors, unauthorised third-party access, or circumstances beyond our control.
If required by law or other obligations beyond our control, we may need to share your Personal Data with third parties such as government authorities. We cannot control how third parties secure your Personal Data in these situations.
Data transmitted over the internet cannot be completely secure. The Company cannot guarantee the security of Personal Data you send to us online.

11. Links to third-party websites

The website contains links to third-party sites and applications that are not under our control. We are not responsible for how these sites or apps collect or process your personal data. This privacy policy does not apply to third-party sites or apps.
Before you use any third-party website or app, we recommend you read their privacy policies. We also suggest you review what personal data you're willing to share with them.

12. Changes to This Policy

Before accessing any third-party websites or apps, we recommend reading their privacy policies. We also suggest being cautious about what personal data you share with them.

Your rights regarding your personal information

You are entitled to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete Personal Data that we no longer need. You may also restrict how we process your personal information.
If you are an EEA resident, please refer to this page:
These rights apply to the information you provide relating to your Personal Data. To exercise any of these rights, you can email us at the address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. If the data is accurate, you can access your Personal Data.
The Company will provide an electronic copy of your Personal Data at no cost. We may charge a reasonable fee for additional copies. Data will be provided electronically if you request it.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If your request could harm another person's rights or freedoms, the Company may refuse your request or limit what we can provide.
Right to rectification
You are entitled to ask us to correct inaccurate or incomplete Personal Data about you, considering the purpose of processing.
Right to erasure
You can request deletion of your Personal Data in these cases: (a) the data is no longer needed for the original purpose; (b) you withdraw consent and we have no other legal basis to process it; (c) you object to processing based on legitimate interests at any time; (d) the data is being processed unlawfully; or (e) the data must be deleted to comply with legal obligations.
This right does not apply if processing is necessary to: (a) fulfil a legal obligation under EU or Member State law, or (b) establish, exercise or defend legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you can ask us to limit how we process it.
If you request a restriction, we will only keep your Personal Data if you consent, or to establish, exercise or defend legal rights, protect another person's rights, or for an important reason of public interest in the EU or a Member State.
Right to data portability
If processing is carried out by automated means and is based on your consent or a contract you are party to, you have the right to access and review your Personal Data.
You can request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. This right does not interfere with the rights or freedoms of others.
Right to object
You have the right to object at any time to processing of your Personal Data based on legitimate interests pursued by us or a third party, including profiling. If we can demonstrate compelling legitimate grounds for processing that outweigh your rights and interests, we may continue processing unless you can show they are outweighed by your rights, freedoms or interests, or by legal claims.
You also have the right to object to direct marketing at any time.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. This does not affect the legality of processing that relied on your consent before withdrawal.
You have the right to lodge a complaint with a supervisory authority in your Member State that protects fundamental rights in relation to Personal Data processing within the EU.
EU and Member State laws may limit your rights relating to Personal Data as detailed in this section 13.
We will provide the information you request under section 13 within one month of receiving your request. We may extend this to two months if needed, depending on the complexity and volume of requests. We will notify you of any extension and the reasons within one month of your request.
Information will be provided free of charge unless your request is unfounded or excessive, particularly if repeated. In such cases, we may charge a reasonable fee to cover administrative costs or decline to respond.
If we doubt your identity, the Company may ask for further information to verify it.