Privacy Policy
Last update: 16.03.2026
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 Cliff Gainpeak (the "Website").
These principles will be upheld:
To be transparent about how we process and collect 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's why we created this website. We use various methods to keep you informed about personal data use.
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@cliff-gainpeak.com
Your personal data will only be used for the purposes outlined in this Policy.
We process your Personal Data to deliver the website and Services to you, including connecting you with third-party trading platforms, improving the site, protecting our rights and interests, meeting regulatory and legal obligations, and supporting the administration and operation of the Services.
We also process your Personal Data to better understand your preferences and needs.
To use important tools to protect your rights regarding Personal Data:
To help you 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 purposes or generally, transfer it to you or a third party, and accommodate your requests.
Protect Your Personal Data:
While we cannot guarantee complete security of your personal data, we're committed to using a range of methods and techniques to help protect it.
Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy describes the Personal Data that Company collects from individuals and how it processes, shares, secures, and manages that information.
This Policy covers 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. This includes management, organisation, and storage of Personal Data.
Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect or seek information from anyone younger than 18, nor do we permit such persons to use our services. If we become aware of information about children, we will delete it promptly.
What Personal Data Do We Hold About You?
When you access our service, channels, or website, we collect your Personal Data. In some cases, we may ask you to provide it directly. In other cases, we gather it by analysing how you use our Services or channels, or by receiving information from our third-party partners.
You don't need to disclose personal information to the company, and there are no consequences for not doing so.
However, you're not required to provide us with personal data. In certain circumstances, if you choose not to supply us with personal data, we may be unable to offer our Services or allow access to the website.
4. What Personal Data Do We Collect? When you visit our website, we gather the following personal information:
This includes information about your online activity log and traffic data (including IP address, access date, access time, and browser type), the language you used, software crash logs, the device you used, and related device information. The information we collect is not personally identifiable and cannot be used to identify you.
Personal Data We Receive From You: any personal data you provide voluntarily 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 trading activity.
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 that allow the Company to process your Personal Data are:
- You've consented to the processing of your personal data for one or more purposes. This applies when you submit personal information through the Website so we can share it with a third-party trading platform.
- The Company or a third party may need to process your data to pursue legitimate interests, such as improving Our Services or defending against legal claims.
- Processing must comply with legal requirements.
Get in touch via email for further information about how we process your data to protect legitimate interests.
Below is a summary of the reasons and legal grounds we may use your Personal Data 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 to pass on 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 us respond to any questions you might have about the Services.
The Company or a third party may need to process personal data to pursue legitimate interests.
3. To meet legal obligations, we process your Personal Data as required by administrative, judicial, or other legal requirements.
To meet legal requirements, processing is necessary.
4. To enhance Our Services
We may use your Personal Data to improve Our Services. This includes crash reports and malfunction data we collect in relation to the Services.
We need to process personal data to serve 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 that align with the requirements of Our Services
Such activities include back-office functions, business development, 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 make decisions on various issues, we use different analytical techniques, including statistical methods.
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 procedures to support and defend legal claims.
We may process your Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and our terms and conditions.
We need to process personal data to pursue 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, storage, and analytics providers, including IP address information.
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 your data 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 our products and services.
The Company may disclose Personal Data to regulatory, local, or other official authorities when necessary to protect the rights or assets of third parties.
We may share your Personal Data with potential investors, buyers, or lenders in connection with any transaction, including the transfer or sale of Company assets or those of any group company, or in the event of a merger, restructuring, consolidation, or bankruptcy of the Company or any group company.
7. Third-party cookies and services
Third-party services, including 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 them 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 files downloaded to your device and deleted when you close your browser. Other cookies are persistent – they remain on your device for a period after you close your browser. We use persistent cookies to recognise you as a returning user and to make it easier for you to access the website again.
Types of Cookies:
They may be used by us based on their intended purpose:
The type of cookie
Cookies are essential
Scope
These cookies are necessary to give you access to the features you've requested and to help you navigate our website. We use them to provide the information, products, and services you've asked for.
They're also required for your device to download and stream data. This allows 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 erased 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 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 performance data and help improve the site, as well as to analyse how our website is 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 block or remove cookies, adjust your browser settings. Below are links to help you configure some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, be aware that certain features 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 required 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 a further 12 months.
We regularly review the Personal Data we hold to confirm it's still required.
9. Transfers of personal information to third-party countries or international organisations
Your personal information may be transferred to countries outside your country of residence (including to third countries or international organisations). The Company takes all necessary steps to protect your personal data and ensure that data subjects can exercise their rights and access effective legal remedies.
These protections and safeguards apply to all residents of 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 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 complies 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 organisations. To request this information, email info@wealthwaydigital.uk
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 that your Personal Data will be protected from all risks. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of your Personal Data. This includes, but is not limited to, disclosure due to transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
We may be required by law or other legal obligations to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control how third parties secure your Personal Data.
Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you send to us online.
11. Hyperlinks to third-party websites
The website includes links to third-party sites and applications. These external 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 those third-party sites or apps.
Before using any third-party website or application, we recommend that you review their privacy policies. We also advise you to consider carefully before sharing any Personal Data with them.
12. Changes to this Policy
When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. 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 your Personal Data, correct any inaccuracies, and delete Personal Data that is no longer necessary. You may also restrict how your personal information is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide about your Personal Data. To exercise your rights, please send an email to the address below.
Access rights
The Company can verify the accuracy of Personal Data being processed about you. If accurate, you can access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed. We may charge a reasonable fee for additional copies. The data will be provided electronically if requested.
Your right to access Personal Data must not interfere with the rights and freedoms of others. If a request would harm another person's rights or freedoms, the Company may refuse the request or limit how we fulfil it.
Right to rectification
The Company can correct inaccurate Personal Data. You can request that we correct any incomplete or inaccurate Personal Data about you, taking into account the reason for processing.
Right to erasure
The following reasons apply: (a) Personal Data is no longer needed for the purpose it was collected for; (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 based on legitimate interests pursued by us or a third party; (d) Personal Data is 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 a legal obligation under EU 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 can ask the Company to limit its processing.
If you request that Personal Data be restricted, it may only be kept if you give consent, or to establish, exercise or defend legal rights, or to protect the rights of another person, or for significant public interest reasons within 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 involved in, you have the right to access your Personal Data you have provided to the Company.
You can request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your right to erasure is not affected by exercising your right to data portability. Data portability does not interfere with the rights or freedoms of anyone else.
Right to object
You have the right at any time to object to processing of your Personal Data based on legitimate interests pursued by the Company or a third party. This includes objecting to profiling based solely on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing, we will not continue unless you can show that our interests 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 the Company to process your Personal Data at any time. This does not affect the lawfulness of processing carried out before you withdrew consent.
You have the right to lodge a complaint with the supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding Personal Data processing within the EU.
EU and Member State laws may limit your rights regarding Personal Data, as detailed in this section 13.
We will provide the information you request under the rights described in section 13 within one month of receiving your request. This timeframe can be extended 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 contradict section 13, information requested under your rights in section 13 will be provided free of charge. If a request is unfounded, excessive or repeated, 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.