Privacy Policy
Last update: 05.05.2026
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 Willow Capitwick (the "Website").
These principles will be upheld:
To be transparent about how we process and collect your personal information:
We want you to have clear information about how we use and process your Personal Data. That's why we created this website. We use various methods to keep you informed about Personal Data practices.
If we think you need specific details, we'll provide them at the right time.
We're happy to answer your questions and explain any legal limitations on data use. You can reach us by email at: info@willow-capitwick.com
Your personal data will be used only for the purposes outlined in this Policy.
We process your Personal Data to provide and improve the website, connect you with third-party trading platforms (the 'Services'), protect our rights and interests, meet regulatory and legal requirements, and conduct administrative activities necessary to deliver the Services.
We also process your Personal Data to better understand your preferences and needs.
To use important tools that protect your Personal Data rights:
To help you exercise your rights, we have substantial resources available. Contact us anytime 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.
Protect Your Personal Information:
While we cannot guarantee complete security of your personal data, we're committed to using multiple methods and techniques to protect it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the types of Personal Data the Company collects from individuals and how it processes, shares, secures, and manages that data.
This Policy applies to information that relates to an identified or identifiable natural person. An identifiable person is someone who can be directly identified or identified through a combination of information we hold or can access.
The Policy defines "processing" as any activity involving the collection or use of Personal Data, including managing, organizing, and storing it.
Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect information from individuals under 18 or permit them to use our services. If we discover information about children, we will delete it promptly.
2. What Personal Data Do We Collect About You?
When you access our services and channels or visit our website, we collect your Personal Data. We may ask for your Personal Data directly in some cases, or we may collect it by analyzing how you use our Services and channels, or by receiving information from our third-party partners.
You are not required to disclose personal information to the company, nor are there any consequences for not doing so.
While you aren't required to provide us with personal data, doing so in certain circumstances may be necessary. Without it, we may not be able to deliver our services or allow you 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, traffic data (including your IP address, access date, access time, and language preference), software crash logs, browser type, and device information. This data is not private information and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily provide when you connect with a third-party online trading platform through Us.
Personal Information You Provide to Third-Party Platforms: this information includes your full name, address, phone number, and email address to facilitate your trades.
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, in accordance with applicable legal requirements.
The company cannot process your Personal Data without a valid legal basis. The legal grounds that allow the company to process your Personal Data are:
- You've consented to the processing of your Personal Data for one or more reasons. This applies 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 data to pursue legitimate interests. For example, this includes improving our services or defending legal claims.
- Processing is required to meet legal obligations.
Contact us by email for more details about how we process your information to protect legitimate interests.
Below is a list of reasons and legal grounds we may use your personal data.
Scope
Legal Basis
To share your personal information with third parties when you request access to digital trading
If you ask us, we may collect Personal Data from you to send to third-party companies.
You've consented to the processing of your personal data for one or more purposes.
2. To answer your requests, questions or concerns
We need your Personal Data to help respond to any questions you may have about our Services.
The Company or a third party has a legitimate interest requiring the processing of this information.
We process your personal data to comply with applicable legal obligations and administrative, judicial, or regulatory requirements.
To meet legal requirements, processing is necessary.
4. To improve our services, we may use your personal data, including crash reports and malfunction information related to the Services.
The Company or a third party's legitimate interests require processing of this data.
5. To prevent fraud and misuse of our services
We need to process personal information to pursue the legitimate interests of the Company or a third party.
6. To perform and manage actions in accordance with Our Services requirements
This includes back-office operations, business development, strategic planning, oversight, and related activities.
The Company or a third party may need to process personal information based on legitimate interests.
7. To conduct analysis, such as statistical analysis
To make decisions on various matters, we use different analytical techniques, including statistical methods.
The Company or a third party's legitimate interests require processing of your information.
To protect our assets, rights, and interests—as well as those of third parties—we process Personal Data to establish and defend legal claims in accordance with applicable laws, regulations, agreements, and our terms and policies.
Personal Data may be processed by us to safeguard our rights, interests, and assets, or those of third parties, in compliance with any applicable laws, regulations, agreements, and conditions, terms, or policies.
The Company or a third party may need to process personal information based on legitimate business interests.
6. Transferring Your Personal Data to Third Parties
The Company may share your Personal Data with third-party service providers, such as hosting and storage providers, and may collect IP address information and user experience analytics.
At your request, we can share specific Personal Data with third-party trading platforms. Your Personal Data will be provided to these platforms in accordance with their privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners to help us enhance and improve our products and services.
If required to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory authorities, local authorities, or other official bodies.
We may share Personal Data with potential investors, buyers, lenders, or other entities within our corporate group in connection with corporate transactions (including asset transfers or sales), mergers, restructurings, consolidations, or bankruptcies affecting the Company or any entity within our 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 similar technologies.
Cookies are small text files placed on your device when you visit our website. We use cookies to understand your preferences and browsing behaviour, improve your user experience, remember your settings, and customize the products and services we offer. Cookies also help us gather statistics and analytics data.
Some cookies we use are session cookies. These are temporary and remain on your device only until you close your browser. Other cookies are persistent—they stay on your device for a set period after you close your browser. Persistent cookies help us recognize you as a returning user and allow you to return to the website more easily.
Types of Cookies:
They may be used by us according to their 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 through 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. These are automatically deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies help us recognize you when you return to our site and remember your preferences.
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
Cookies for performance
Scope
We use cookies to collect statistics about site performance and improve your experience. They also help us analyze how our website is being used.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are removed when you close your browser, while others remain active indefinitely.
Cookies are blocked, or removed
To block or remove cookies, adjust your browser's settings. Below are links to help you configure the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain features or the entire Website may not function as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. The retention of personal data about You
The Company will retain your Personal Data as long as necessary to fulfil the purpose 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 12 months. If you consent, we'll continue sharing your data for an additional 12 months.
We regularly review retained Personal Data to confirm it's no longer required.
9. Transfers of Personal Information to Third-Party Countries or International Organizations
Your personal information may be transferred to other countries—for example, your data may be transmitted to a third country (a jurisdiction outside where you reside) or to international organizations. We take all necessary steps to protect your personal data and ensure that users can exercise their 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 organization that the EU Commission has determined provides adequate protection for Personal Data transferred under Article 45(3) of Regulation 2016/679 of the European Parliament and Council (27 April 2016), known as 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 approved by the EU Commission under Article 46(2)(c) of the GDPR. You can review the EU Commission's approved 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 information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organizations. Send an email to info@wealthwaydigital.uk
10. Security of Your Personal Data
We have implemented appropriate organizational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.
While we take security seriously, we cannot guarantee error-free protection of your Personal Data. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data, including losses from transmission errors, unauthorized third-party access, or other circumstances beyond our control.
We may be required by law or other obligations beyond our control to disclose your Personal Data to third parties, such as government authorities. We cannot control how third parties secure your Personal Data in these situations.
Data transmission over the internet cannot be completely secure. We cannot guarantee the security of Personal Data you send to us online.
11. Hyperlinks to Third-Party Websites
Links to third-party websites and applications are available on our website. These third-party services are not operated by the Company, and we are not responsible for how they collect or process your personal data. This Privacy Policy does not apply to their practices.
Before accessing or using any third-party website or application, we recommend reviewing their privacy policies. Please exercise caution when sharing personal data with these services.
12. Policy Changes
Before accessing any third-party websites or apps, we recommend reviewing their privacy policies. Please also consider what Personal Data you choose to 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 require. You may also restrict how we process your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide regarding your Personal Data. You may exercise your rights by submitting a written request to the email address below.
Access rights
We can verify the accuracy of Personal Data we process about you. If accurate, you may access your Personal Data.
We will provide an electronic copy of the Personal Data currently being processed at no cost. Additional copies may be subject to a reasonable fee. Data will be provided electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If granting your request would harm another person's rights and freedoms, we may refuse the request or limit our response.
Right to rectification
We are entitled to correct inaccurate Personal Data. You may request that any incomplete or inaccurate Personal Data about you be corrected, considering the purpose of processing.
Right to erasure
The following circumstances apply: (a) Personal Data are no longer necessary for the purpose for which they were collected; (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 processing of Personal Data about you based on legitimate interests pursued by us or a third party; (d) Personal Data are processed unlawfully; or (e) Personal Data must be deleted to comply with a legal obligation.
This right does not apply if processing is necessary (a) to fulfil an obligation required by 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 us to restrict its processing.
If you request that Personal Data be restricted, we may only retain it if you consent, or to establish, exercise, or defend legal rights, or to protect the rights of another individual, or for significant public interest reasons within the European Union 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 review your Personal Data.
You may request that your Personal Data be transferred directly from us to another controller, if technically feasible. Exercising your right to data portability does not affect your right to erasure. Data portability does not interfere with the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of your Personal Data based on legitimate interests pursued by us or a third party. This includes objections to profiling based solely on legitimate interests. If we can demonstrate compelling legitimate grounds for processing, we will not stop unless you can show that your rights, freedoms, or interests outweigh ours, or you are exercising, establishing, or defending legal rights.
Regarding direct marketing, you have the right at any time to object to processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. This does not affect the lawfulness of processing based on your prior consent.
You are entitled to lodge a complaint with your supervisory authority.
You may appeal to a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding Personal Data processing within the European Union.
European Union and Member State laws may limit your rights regarding Personal Data, as detailed in this section.
We will provide the requested information within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the complexity and volume of requests. We will notify you of any extension and the reasons within one month of receiving your request.
Unless otherwise required by law, information requested under your rights will be provided free of cost. If a request is unjustified, excessive, or repetitive, we may charge a reasonable fee to cover administrative costs. We may also decline to act.
If we have doubts about your identity, we may request further information to verify it.