Privacy Policy
Last update: 13.08.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy is designed to inform you about how we collect and store the information you provide through the website River Wertholm (the "Website").
The following principles will be upheld:
To be transparent about how we process and collect your personal information:
We want you to be well-informed about how your Personal Data is used and processed. That is why we have created this website. To achieve this, we use a variety of methods and procedures to provide you with relevant information about the use of your Personal Data.
If we determine that you need specific details, we will provide them to you at the appropriate time.
We are happy to answer any questions you may have and will clarify any concerns regarding limitations imposed by law. You can reach us by email at the address below: info@riverwertholm.com
Personal Data will be used only for the purposes outlined in this Policy.
We may process your Personal Data for a range of purposes, including to provide the website and connect you with third-party trading platforms (the 'Services'), to improve the site, protect our rights and interests, support the maintenance and delivery of the Services, meet applicable regulatory or legal obligations, and carry out administrative and business activities related to the Services.
We also process your Personal Data to better understand your preferences and needs.
To make use of significant tools to safeguard your rights with respect to Personal Data:
To exercise your rights, we have the necessary resources in place. Contact us at any time to submit a request regarding your personal data. We can modify or delete it, restrict its use for specific or general purposes, or transfer it to you or a third party. We are committed to accommodating your requests.
Secure Your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can assure you that we will continue to employ a range of methods and measures to keep your Personal Data protected.
Our Privacy and Security Policy is complete.
1. The Scope?
This policy describes the types of Personal Data the Company collects about individuals, how it processes and shares that data with third parties, and how it secures those processes.
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 a combination of additional information we hold or are able to access.
This 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 seek or collect information from individuals younger than 18, nor do we knowingly permit such individuals to use our services. If we become aware that we have collected information from a minor, we will delete it as promptly as possible.
2. What Personal Data Do We Hold on You?
When you access our services and 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 it by analyzing how our Services and service channels are used, or by receiving your information from our third-party partners.
3. There is no requirement to disclose personal information to the company, along with the associated consequences.
You are not required to provide Us with any personal data. However, in certain circumstances, choosing not to do so may limit Our ability to offer the Services or restrict users from accessing 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 your IP address, date of access, time of access, and date of access), the language you used, software crash logs, the type of browser used, and information about the device you utilized. This information is not personal and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily 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 facilitate trading: this 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 described in this section, in accordance with the applicable legal basis.
Without a valid legal basis, the Company is not permitted to use your Personal Data. The legal grounds upon which the Company may process your Personal Data are as follows:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information through 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 pursue their legitimate interests — for example, to improve Our Services or to defend legal claims.
- Processing is required to fulfil a legal obligation.
Contact us by email for more details about the processing required to protect legitimate interests.
Below is a list of the reasons and legal grounds on which we may use the information you provide us. Personal Data.
Scope
Legal Basis
1. To share your personal information with third parties at your request in order to access digital trading
If you request it, we may collect Personal Data from you to forward to third-party companies.
You have given your consent to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions, or concerns
Personal Data is necessary to address any questions you may have regarding the Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
3. To meet any legal obligation or administrative, judicial, or regulatory requirements, Personal Data is processed in accordance with applicable legal obligations.
To meet legal obligations, processing is required.
4. To Enhance Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash reports and malfunction data we collect in connection with the Services.
Processing is necessary to fulfil the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary to fulfil 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, strategic decision-making, oversight mechanisms, and more.
Processing is necessary to serve the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
To make decisions on various matters, we employ a range of analytical techniques (including statistical methods).
Processing is necessary to fulfil 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 may process Personal Data in order to establish and defend legal claims.
Personal Data may be processed to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, conditions, terms, or policies.
Processing is necessary to serve the legitimate interests of the Company or 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 user experience analysis.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you have submitted to us directly to those third-party trading platforms. The use of your Personal Data will be governed by their respective 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 enables the Company to access the resources needed to enhance and improve the products and services offered to its customers.
Where necessary to protect the rights or assets of third parties, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, in the event that a relevant transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Cookies and Third-Party Services
Third-party services, such as advertisers or analytics companies, may be used in connection with our website. These companies may also make use of cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve your user experience, remember your settings, and tailor the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire once you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period of time after your browser is closed. They help the website recognize you as a returning user and make it easier for you to navigate back to the site.
Types of Cookies:
They may be used by us according to their purpose:
The type of cookie
Cookies are strictly necessary
Scope
These cookies are necessary for accessing the features you've requested and for navigating our website. They are used to deliver the information, products, and services you've asked us to provide.
They are required for your device to download and stream data, allowing you to navigate the website, use its features, and return to pages you've 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 deleted when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and to save your settings and preferences.
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 deleted when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to conduct analysis on our website.
Additional Information
Cookies store anonymous data that is not associated with any identified or identifiable individual. They can be removed when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or removed
To block or remove cookies, you'll need to adjust your browser settings. Below are links to help you through the process for some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please be aware that some or all of the Website's features and functions 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 for which it was collected, as described in this Policy, or for longer periods as permitted by applicable laws, regulations, and orders.
We will 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 an additional 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-Party Country or International Organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — meaning a country other than the one in which you reside — or to international organizations. Company takes all necessary steps to safeguard the personal data you provide and to ensure that users can assert their rights and access effective legal recourse.
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 EU Commission has determined provides an adequate level of protection for Personal Data, 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 was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These clauses 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.
For information about the security measures we use to protect your Personal Data when it is transferred to third-party countries or international organisations, please contact us at info@wealthwaydigital.uk
10. Personal Data Security
We have implemented appropriate organizational and technical measures to protect your Personal Data, including prevention of accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorized access by third parties, or any other cause beyond our control.
In the event of legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control how such third parties handle the security of your Personal Data in these circumstances.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you transmit to us online.
11. Hyperlinks to Third-Party Websites
Links to third-party websites and applications may be found on our website. These sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these third-party websites or apps. This Policy does not apply to actions taken through such sites or apps.
When visiting any third-party website or application, we recommend reading their privacy policy before choosing to access or use their services. We also encourage you to exercise caution when providing any Personal Data to them.
12. Amendments to This Policy
Before accessing or using any third-party websites or apps, we recommend reviewing their privacy policies. We also suggest carefully considering what Personal Data you share with them.
13. Your Rights Regarding Your Personal Information
You have the right to request that we verify the accuracy of the Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we no longer require. You may also restrict the types of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, please send a written request to the email address below.
Access rights
The Company can verify the accuracy of the Personal Data being processed about you. If such data is being processed, you may access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.
Right to rectification
The Company may correct inaccurate Personal Data. You have the right 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 needed 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, on grounds specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by us or a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the Company.
This right does not apply where processing is necessary (a) to comply with 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 of your Personal Data.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal rights, or to protect the rights of another individual, 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 your consent or a contract to which you are a party, you have the right to receive and review the Personal Data you have provided to the Company.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure, nor does it infringe the rights or freedoms of others.
Right to object
You have the right, at any time, to object to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those interests. If we cannot demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where the processing is not necessary for the establishment, exercise, or defence of legal rights, we will cease such processing.
Concerning direct marketing, you have the right at any time to object to the processing of Personal Data about you.
Right to withdraw consent
You may withdraw your consent for 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 prior to its withdrawal.
You have the right to lodge a complaint with the relevant 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.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in section 13.
We will provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months if necessary, depending on the complexity and volume of requests. We will notify you of any such extension, along with the reasons, within one month of receiving your request.
Unless otherwise limited by section 13, information provided in response to a request made under section 13 will be provided free of charge. If a request is unfounded or excessive, particularly where requests are repetitive, we may charge a reasonable fee to cover administrative costs, or we may decline to act.
If we have reasonable doubts about the identity of the person submitting a request, the Company may ask for additional information to verify their identity.