Privacy Policy
Last update: 23.04.2026
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect, use, and store the information you provide through the Spruce Wealthwick website (the "Website").
We are guided by the following principles:
To be transparent about how we collect and process your personal information:
We want you to have the information you need to make informed decisions about how your Personal Data is used and processed. That is why we created this website. To support this, we use a range of methods and procedures to provide clear, relevant information about the handling of Personal Data.
If we determine that you need specific details, we will provide that information at the appropriate time.
If you have any questions, we will be pleased to assist and provide any clarification required, subject to applicable legal limitations. You can contact us by email at the address below: info@spruce-wealthwick.com
Personal Data will be used only for the purposes set out in this Policy.
We may process Personal Data for a variety of purposes, including providing you with access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, supporting the operation and delivery of the Services, meeting applicable legal and regulatory requirements, and carrying out administrative and business functions related to the provision and use of the Services.
We also process Personal Data to better understand your preferences and needs.
To access important tools that help protect your rights regarding Personal Data:
To support the exercise of your rights, we have dedicated substantial resources to this process. Contact Us at any time to request access to your Personal Data. We can update or delete your information, stop using it for specific or broader purposes, and transfer it to you or to a third party. We will make every reasonable effort to accommodate your requests.
Secure your Personal Data:
Although we cannot guarantee the absolute security of your Personal Data, we are committed to using a range of measures and safeguards to help keep your Personal Data protected.
Our Privacy and Security Policy sets out our practices in full.
1. The Scope?
This policy explains the types of Personal Data the Company collects about individuals, how that information is processed, when it may be shared with third parties, and the measures taken to keep it secure.
This Policy applies to information relating to an identified or identifiable individual. An identifiable individual is someone who can be identified directly, or indirectly through additional information that we hold or can reasonably access.
In this Policy, "processing" refers to any operation involving Personal Data, including its collection, use, organization, structuring, and storage.
Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals under 18 or permit them to use our services. If we become aware that we have collected information about a child, we will delete it as soon as reasonably possible.
2. What personal Data Do We Have on You?
When you use our services or 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 reviewing how our services or channels are used or by receiving your information from trusted third-party partners.
3. You are not required to provide the company with any personal information, and there are no consequences for choosing not to do so.
However, you are not required to provide us with any personal information. In some cases, if you choose not to provide certain personal information, we may be unable to deliver the Services, and users may not be able to access the website.
4. What Personal Data do we collect? When you visit our website, we may collect the following personal information:
This includes information about your online activity records, traffic data (including your IP address, the date and time of access), your selected language, software crash reports, the type of browser you use, and details about the device you used. The information collected does not constitute private information and cannot be used to identify you.
Personal Data We receive from you: any personal data you choose to 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 enable trading: this information includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing Personal Data
The Company processes your Personal Data for the purposes set out in this section and on the legal basis that applies to each purpose.
If there is no valid legal basis, the Company cannot process your Personal Data. The legal grounds the Company relies on to 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 provide personal information through the Website so that we can share it with a third-party trading platform.
- The Company or a third party may need to process information to pursue legitimate interests, such as improving Our Services or responding to legal claims.
- Processing must meet an obligation of law.
Contact us by email for more information about the processing required to protect legitimate interests.
Below is a list of the purposes for which we may use the Personal Data you provide to us, along with the legal basis for doing so.
Scope
Legal Basis
1. To share your personal information with third parties at your request so you can access digital trading services
If you request this, we may ask you to provide Personal Data so it can be passed on to third-party companies.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
We use Personal Data to address any questions you may have about the Services.
The Company’s legitimate interests, or those of a third party, must be processed.
3. To comply with legal, administrative, or judicial requirements, Personal Data is processed as necessary to meet those obligations.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services Personal
Data may be used to help us improve Our Services. This includes, among other things, crash reports and malfunction reports we collect in connection with the Services.
Processing is necessary to support the Company’s legitimate interests or those of a third party.
5. To stop fraud and misuse of Our Services
Processing is necessary to support the Company’s legitimate interests or those of a third party.
6. To carry out and manage activities required to deliver Our Services
These activities include back-office operations, business development, strategic planning, oversight processes, and related functions.
Processing is necessary to support the Company’s legitimate interests or those of a third party.
7. To carry out analyses, including statistical analysis
We use a range of analytical methods, including statistical techniques, to support decision-making on various matters.
Processing is necessary to support the Company’s legitimate interests or those of a third party.
8. To protect our assets, rights, and interests, as well as those of third parties, we may process Personal Data to establish, exercise, or defend legal claims.
We may also process Personal Data to protect our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing is necessary to serve the Company’s legitimate interests or those of a third party.
6. Transfer of Personal Data to Third Party
The Company may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, providers of IP address services, and user experience analytics providers.
You may also request that we share specific Personal Data relating to you with third-party trading platforms. In these cases, we will provide the Personal Data you have submitted to us to those third-party trading platforms. Any use of your Personal Data by those platforms will be governed by their own privacy policies. Your Personal Data may be shared with more than one trading platform.
The Company may also share Personal Data with affiliated entities or business partners. This may enable the Company to access the resources required to develop, improve, and enhance the products and services it offers to its customers.
Where necessary to protect the rights of third parties or Company assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with prospective investors, purchasers, or lenders to the Company or any affiliated company in connection with the same type of transaction, including the sale or transfer of assets of the Company or any affiliated company, or as part of a merger, reorganization, consolidation, or insolvency proceeding involving the Company or any affiliated business.
7. Cookies and services from third parties
We may use third-party services, including advertising partners on our website and analytics providers. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They help collect information about your preferences and browsing activity so we can improve your user experience, remember your settings, and tailor the products and services that may be of interest to you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporarily stored on your device and remain active only until you close your browser. Other cookies are persistent cookies. Persistent cookies stay on your device for a period of time after your browser is closed. They help the Website recognize you as a returning user and allow you to access the website more easily.
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 accessing the features you’ve requested and moving through our website. They help us deliver the information, products, and services you’ve asked for.
They are also needed for your device to download and stream data. This allows you to browse the website, use its features, and return to pages you previously visited.
Additional Information
Cookies may collect Personal Data, such as your username and the date of your last login, to confirm that you are signed in to the site. These Cookies are 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 settings and preferences.
Additional Information
Cookies may collect Personal Data, such as your username and the date of your last login, to verify that you are signed in to the site. These Cookies are deleted when you close your web browser (session Cookies).
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical information about the site's performance and help improve it. They also allow Us to analyze our website.
Additional Information
Cookies may store anonymous information that cannot be linked to an identified or identifiable individual. Some are deleted when you close your browser, while others remain valid indefinitely.
Cookies are blocked or have been deleted
To allow or clear cookies, you’ll need to update your browser settings. Below, you’ll find links with instructions for some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all of the Website’s functions and features may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently respond to do-not-track signals.
8. How long we keep your personal information
The Company will retain your Personal Data only for as long as needed to carry out the purposes for which it is processed, as outlined in this Policy, or for longer where permitted under applicable laws, regulations, internal policies, or binding orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your information for an additional 12 months.
We review the Personal Data we hold on a regular basis to confirm that it is no longer required.
9. Transfers of personal information to another country or to an international organization
Your personal information may be transferred to other countries, meaning your personal data may be shared with a country other than the one where you live or with an international organization. The Company takes all necessary measures to protect the Personal Data you provide and to ensure that individuals can exercise their rights and have access to effective legal remedies.
These safeguards and protections are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organization that the European Commission has recognized as providing an adequate level of protection for Personal Data transferred to it, 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 carried out under a legally binding and enforceable agreement between public bodies or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out using standard data protection clauses approved by the European Commission under Article 46(2)(c) of the GDPR. You can review these 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 it is transferred to third countries or international organizations. To request this information, please email info@wealthwaydigital.uk
10. Security of Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data. These measures are designed to help prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.
That said, we cannot guarantee that the security of your Personal Data will always be maintained without interruption or error. We are also not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data, including, without limitation, disclosure caused by transmission errors, unauthorized access by a third party, or other circumstances beyond our reasonable control.
Where required by law or in situations beyond our control, we may need to disclose your Personal Data to third parties, including public authorities. In such cases, we are unable to oversee or guarantee the level of protection applied to your Personal Data by those third parties.
No method of transmitting Personal Data over the internet is entirely secure. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Hyperlinks to websites belonging to third party websites
The website may include links to third-party websites and applications. These websites and applications are not operated or monitored by the Company. We are not responsible for how these third parties collect or process Personal Data, and this Policy does not apply to any activities carried out through those websites or applications.
If you choose to visit any third-party website or application, we recommend reviewing its privacy policy before accessing or using it. We also encourage you to consider carefully before providing any Personal Data to third parties.
12. Modifications to this Policy
Before visiting any third-party website or using any third-party app, we recommend reviewing their privacy policies so you can decide whether to access or use their services. We also suggest considering this information before sharing any Personal Data with them.
13. Your rights with respect to your personal information
You have the right to ask us to confirm whether we collect Personal Data about you, to correct any inaccuracies, and to delete any Personal Data that we no longer need. You may also request limits on how your personal information is processed.
If you live in a region where specific privacy rights apply, 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, you may contact us by email at the address below.
Access rights
The Company can confirm whether your Personal Data is being processed and, if so, provide you with access to that 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. If you request it, the information will be provided electronically.
Your right to access Personal Data must not adversely affect the rights and freedoms of others. If fulfilling a request would negatively affect another person’s rights and freedoms, the Company may refuse the request or limit the extent to which it can be fulfilled.
Right to rectification
The Company may correct inaccurate Personal Data. You also have the right to request that incomplete Personal Data relating to you be completed, taking into account the purpose of the processing.
Right to erasure
This right may apply in the following circumstances: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object, for reasons related to your particular situation, to the processing of your Personal Data where that processing is based on the legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased to comply with a legal obligation binding on the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under applicable law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where processing has been restricted, Personal Data may only be stored unless you give consent for further processing, or where processing is necessary to establish, exercise, or defend legal claims, to protect the rights of another individual, or for reasons of substantial public interest under applicable law.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company and to review it.
You also have the right to 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. The right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You have the right, at any time, to object to the processing of your Personal Data where that processing is based on the legitimate interests pursued by the Company or a third party. This includes profiling to the extent that it is based on those legitimate interests. If we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or if the processing is required for the establishment, exercise, or defence of legal claims, we may continue the processing.
For direct marketing purposes, you have the right at any time to object to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your consent was withdrawn.
You have the right to file a complaint with the appropriate privacy oversight authority.
You may also submit a complaint to a supervisory authority established to protect individuals’ fundamental rights in relation to the processing of Personal Data.
Applicable laws may limit your rights in relation to your Personal Data, as described in this section 13.
We will provide the information requested under the rights set out in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two additional months where necessary, depending on the nature of the request and the number of requests received. If an extension applies, we will notify you within one month of receiving your request and explain the reasons for the delay.
Unless otherwise permitted under section 13 and applicable law, the information you request under your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information to verify identity.