Privacy Policy
Last update: 22.04.2026
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 Cliffs Fundmere (the "Website").
These principles will be upheld:
To be transparent about how we process and collect your personal information:
We want you to be able to make informed choices about how we use and process your personal data. That's why we created this website. We use different methods to give you clear information about your personal data and how it's handled.
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 our data practices and any legal limits that apply. Contact us by email at: info@cliffs-fundmere.com
Personal data will only be used for the purposes outlined in this Policy.
We may process your Personal Data for various purposes, including providing the website and Services (which connect you with third-party trading platforms), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and supporting administrative and business activities. 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 key tools that protect your Personal Data rights:
To exercise your rights, we have substantial resources available. Contact us at any time to request access to your personal data. We can modify or delete it, stop using it for specific purposes or general purposes, transfer it to you or a third party, and accommodate your requests.
Secure your Personal Data:
While we cannot guarantee complete security of your Personal Data, we take every reasonable step to protect it using industry-standard methods and techniques.
Our Privacy and Security Policy provides full details.
1. The Scope?
This policy outlines what 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 person 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. We do not knowingly collect information from anyone younger than 18 or permit such persons to use our services. We will delete any information we discover about children as soon as possible.
2. What personal Data Do We Have on You?
When you access our services, channels, or website, we collect your Personal Data. We may ask you to provide Personal Data directly in some cases. In other cases, we gather your Personal Data by analysing how you use our Services or channels, or by receiving information from our third-party partners.
You don't need to share your personal information with the company, and there are no consequences if you choose not to.
You aren't required to provide us with any personal data. However, in certain circumstances, not supplying us with personal data could prevent us from offering our services or limit your access to the website.
4. What Personal Data Do We Collect? When you visit our website, we gather the following personal information about you:
This includes information about your online activity log, traffic data (including your IP address, date of access, time of access, and browser language), software crash logs, the type of browser you used, and details about your device. This information is not private and cannot be used to identify you.
Personal Data We Receive From You: any personal information you choose to provide when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms: this includes your full name, address, phone number, and email address to enable trading services.
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 the applicable legal basis.
The Company cannot process your Personal Data without a legal basis. The legal grounds that allow the Company to process your Personal Data are:
- You've consented to your Personal Data being processed for one or more reasons. This applies when you submit personal information through our Website so we can transfer it to a third-party trading platform.
- We may process your information to fulfil our legitimate interests or those of a third party. This includes improving our services and defending legal claims.
- Processing must meet an obligation of law.
Contact us by email for more details about how we process and protect your legitimate interests.
Below is a list of the reasons and legal grounds we may use your personal data for.
Scope
Legal Basis
To share your personal information with third-party companies when you request access to digital trading
If you ask us to, we may collect Personal Data from you to send it to third-party companies.
You have consented to the processing of your Personal Data for one or more reasons.
2. To address your requests, questions or concerns
We need your Personal Data to help answer any questions you may have about the Services.
The Company or a third party requires processing of legitimate interests for operational purposes.
We process your personal data to meet legal obligations and to comply with administrative, judicial, or other legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To enhance Our Services, Personal
Data may be used by us to enhance Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
The Company or a third party has a legitimate interest in processing this data.
5. To stop fraud and misuse of Our Services
We need to process your data to protect the legitimate interests of the Company or a third party.
6. To perform and manage actions that meet the requirements of Our Services
This includes back-office functions, business development activities, strategic decision-making, oversight mechanisms, and similar operations.
We need to process personal data to protect the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
To inform our decision-making on various matters, we use a range of analytical techniques, including statistical methods.
We need to process personal data based on 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 process Personal Data to establish and defend legal claims in accordance with applicable laws, regulations and agreements.
We may process your Personal Data to safeguard our rights, interests and assets, or those of third parties, in compliance with any 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 Party
The Company may share your Personal Data with third-party service providers such as hosting and storage providers, including IP address information and user experience analytics.
You can request that we share specific Personal Data about you with third-party trading platforms. We will disclose your Personal Data to these platforms, and their 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 obtain resources needed to enhance and improve our products and services.
The Company may disclose Personal Data to regulatory, local, or other official authorities where necessary to protect the rights of third parties or safeguard assets.
We may additionally share Personal Data about you with potential investors, buyers, or lenders to the Company or any member of our group in connection with a proposed transaction (including the transfer or sale of Company assets or group assets) or as part of any merger, restructuring, consolidation, or insolvency involving the Company or any other group member.
7. Cookies and services from third parties
Third-party services, such as advertisers and analytics providers, may be used on our website. These companies may also use cookies and similar technologies.
Cookies are small text files stored on your device when you visit our website. We use cookies to understand your preferences and browsing behaviour, improve your experience, remember your settings, and personalise 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 deleted from your device when you close your browser. Other cookies are persistent—they remain on your device after you close your browser. We use persistent cookies to recognise you as a returning user and to help you access the website more easily on future visits.
Types of Cookies:
They may be used by us based on their purpose:
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for you 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 that you're logged in to 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 each time 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 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 gather statistical data about site performance and to help improve it. They also allow us to analyse 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, whilst others remain indefinitely.
Cookies are blocked or removed
To prevent or remove cookies, adjust your browser settings. Below are links to help you with 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 of processing it, as outlined in this Policy, or for longer periods as permitted by applicable law, regulations, policies, and relevant orders.
We'll share your information with third-party trading platforms for 12 months. If you consent to this, we'll continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it's no longer required.
9. Transfers of personal information to third-party countries or international organisations
Your personal information may be transferred to other countries—meaning your personal data could be sent to a third country (any country other than where you currently live) or to international organisations and jurisdictions. 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 everyone residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection of Personal Data 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 in accordance with a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
- The transfer was completed in compliance with the standard data protection clauses approved by the EU Commission under Article 46(2)(c) of the GDPR. You can view 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 details about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk for further information.
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.
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 arising from the use or disclosure of Personal Data, including those resulting from transmission errors, unauthorised 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 public authorities. We cannot control how third parties secure your Personal Data in such situations.
Data transmitted over the internet cannot be guaranteed completely secure. We cannot ensure the security of Personal Data you send to us online.
11. Hyperlinks to websites belonging to third party websites
The website contains links to third-party sites and applications that are not operated by the Company. We are not responsible for how these third parties collect or process your Personal Data. This Policy does not apply to their sites or apps.
Before using any third-party website or app, we recommend you review their privacy policies. We also advise you to consider carefully before providing any Personal Data to them.
12. Modifications to this Policy
When visiting any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use them. We also suggest reviewing what Personal Data you share with them.
13. Your rights with respect to your personal information
You are entitled to request us to verify the accuracy of Personal Data being collected about you, to correct any inaccuracies, and to delete all Personal Data not required by us. 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 these 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 may access your Personal Data.
The Company will provide an electronic copy of your Personal Data currently being processed and may charge a reasonable fee for 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 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
You are entitled to request that the Company correct inaccurate Personal Data. You may demand that any incomplete Personal Data concerning you be corrected, taking into account the reason for processing.
Right to erasure
The following reasons apply: (a) Personal Data are no longer necessary for the purpose for which they were collected; (b) you withdraw consent and there is no legal basis for processing; (c) you object at any time to processing of Personal Data 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 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 limit its processing.
If you request that Personal Data be restricted, it may only be retained if you consent, or to establish, exercise or defend legal rights, or to protect the rights of another person, or for reasons of significant public interest 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 obtain and reuse your Personal Data provided to the Company.
You may request that the Company transfer your Personal Data directly to another controller, if technically feasible. Exercising your right to data portability does not affect the rights granted under the right to erasure. The right to data portability does not adversely affect the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of Personal Data based on legitimate interests pursued by the Company or a third party. This includes objections to profiling based solely on legitimate interests. If the Company establishes compelling legitimate grounds for processing, we cannot continue unless we can demonstrate that these grounds 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 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 will not affect the lawfulness of processing based on your consent before 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 Personal Data processing within the European Union.
The laws of the European Union and Member States 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 period 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 and the reasons within one month of receiving your request.
As long as it does not conflict with the provisions of this section, the information you request will be provided free of charge. If your 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, the Company may request further information to verify it.