Dusk Fundholm

Privacy Policy

Last update: 01.04.2026

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 the information you provide through the website Dusk Fundholm (the "Website").
We uphold the following principles:

To be transparent about how we process and collect your personal information:

We want to ensure you can make informed decisions about how your Personal Data is used and processed. That's why we've created this website. We use various methods and procedures to provide you with relevant information about Personal Data usage.
Should we believe you need specific details, we'll provide information at the appropriate time.
We're happy to answer any questions and offer clarifications regarding any legal limitations that may apply. Please get in touch via email at: info@dusk-fundholm.com

Your personal data will be used only for the purposes specified in this Policy.

Personal Data may be processed by us for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services.
We also process Personal Data to better understand your preferences and needs.

To utilise important tools that protect your rights regarding personal data:

To help you exercise your rights, we have substantial resources at your disposal. Contact us at any time to request your personal data or to exercise your data rights. We can modify or delete your information, cease using it for specific or general purposes, or transfer it to you or a third party. We're committed to accommodating your requests.

Protect Your Personal Data

Whilst we cannot guarantee absolute security of your personal data, we commit to employing a range of methods and techniques to safeguard it effectively.
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 information. This policy applies to information that relates to an identified or identifiable individual. 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 the management, structuring, 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 persons under 18, nor do we permit such individuals to use our services. Should we become aware that we hold information about a child, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services and channels or visit our website, we collect your Personal Data. We may request your Personal Data in certain circumstances, or we may gather it by analysing your use of our Services and channels, or by receiving information from our third-party partners.

3. There is no requirement to disclose personal information to the company, nor any associated consequences.

However, you're not required to provide us with any personal data. In certain circumstances, if you choose not to supply us with personal data, this may prevent us from delivering 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:

This includes information about your online activity log, data about your traffic (including IP address, date of access, time of access, and browser type), the language you used, software crash logs, the type of browser used, and details about your device. The information we collect is not personal data and cannot be used to identify you.
Personal Data We Receive From You: any personal data you provide to us at your own discretion when you connect with a third-party online trading platform through us.
Personal Information You Provide to Third-Party Platforms to Facilitate Trading: this information 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 outlined in this section, and in accordance with the applicable legal basis.
The company cannot process your Personal Data without a legal basis. The legal grounds on which the company is able 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 submit personal information through the Website so that we can transfer it to a third-party trading platform.
  • The Company or a third party may need to process data to fulfil their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
  • Processing must comply with legal requirements.

Contact us via email for further details on how we process your information to protect our legitimate interests.
Below is a summary of the reasons and legal grounds under which we may use the personal data you provide.

Scope

Legal Basis

If you request access to digital trading services, we may ask for your personal information to share with third-party partners on your behalf

You have consented to the processing of your Personal Data for one or more purposes.

2. To address your requests, questions or concerns
We need your Personal Data to help us respond to any questions you may have about the Services.

The Company or a third party requires processing of legitimate interests.

3. To meet legal obligations or administrative, judicial or legal requirements. Personal Data is processed to satisfy any applicable legal obligations.

To meet our legal obligations, processing is necessary.

4. To enhance Our Services, we may use your Personal Data to improve Our Services. This includes, amongst other things, any crash reports or malfunction data that we collect relating to the Services.

The Company or a third party has a legitimate interest that requires the processing of your information.

5. To prevent fraud and misuse of our services

We need to process your data to protect the legitimate interests of the Company or those of 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 activities, strategic decision-making, oversight mechanisms, and related operational tasks.

We may need to process your personal data to protect the legitimate interests of the Company or a third party.

7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different matters.

We must process personal data to protect 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 have developed procedures to establish 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 all applicable laws, regulations, agreements, and our terms 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 Parties

The Company may share your Personal Data with third-party service providers, such as hosting and storage providers, to support our operations and analyse user experiences.
You can request that we share specific Personal Data about you with third-party trading platforms. When you do so, we will provide your Personal Data to these trading platforms in accordance with their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities and business partners to help us enhance and improve our products and services.
We may disclose Personal Data to regulatory authorities, local authorities, or other official bodies where necessary to protect the rights or assets of third parties.
Additionally, we may share Personal Data about you with potential investors, buyers, or lenders to the Company or other group entities in connection with corporate transactions, including the transfer or sale of Company assets or group company assets, or as part of any merger, restructuring, consolidation, or insolvency involving the Company or any other group business.

7. Third-party cookies and services

Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also use cookies or other tracking technologies.
Cookies are small text files placed on your device when you visit our website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your preferences, and personalise the products and services we offer. Cookies are also used for statistical and analytical purposes.
We use two main types of cookies. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies remain on your device for a set period 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 according to their intended purpose:

The type of cookie

Cookies are essential

Scope

These cookies are necessary to enable you to access the features you've requested and navigate our website. They're used to deliver the information, products and services you've asked for.
They're required for your device to download and stream data. This allows 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 that you're logged in to the site. They're automatically deleted when you close your web browser (session cookies).

The type of cookie

Functionality Cookies

Scope

Cookies enable us to recognise you on each visit to our site and remember your preferences.

Additional Information

Cookies collect Personal Data, such as your username and last login date, to confirm you remain logged in to the site. These are 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 on site performance and to enhance your experience. 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 individual. Some are removed when you close your browser, whilst others remain indefinitely.

Cookies are blocked, or removed
To block or remove cookies, adjust your browser's settings. Below are links to guide you through the process for some of the most popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

However, be aware that certain functions or the entire Website's features may not work as expected if this occurs.

ONLINE TRACKING NOTICE
This service currently does not support do-not-track signals.
8. The retention of your personal data

The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing, as described in this Policy, or for longer periods as permitted by applicable law, regulations, and court orders.
We'll 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 a further 12 months.
We regularly review the Personal Data we hold to ensure it remains necessary.

9. Transfers of personal information to third-party countries or international organisations

Your personal information may be transferred to other countries, including to third countries or international organisations outside the jurisdiction where you reside. We take all necessary steps to safeguard your personal data and ensure that data users can assert 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 (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
  • The transfer is carried out in accordance with 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 adopted by the EU Commission under Article 46(2)(c) of the GDPR. You can view the clauses adopted by the EU Commission 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 employs to protect your Personal Data when transferred to third-party countries or international organisations. Please send an email to info@wealthwaydigital.uk for further details.

10. Security of Personal Data

We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without any issues. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of your Personal Data, including where such disclosure occurs due to transmission errors, unauthorised third-party access, or circumstances beyond our control. Where required by law or other obligations beyond our control, we may need 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. No data transmission over the internet is completely secure. The Company cannot guarantee the security of Personal Data you transmit to us electronically.

11. Hyperlinks to third-party websites

The website contains links to third-party sites and applications that are not under our supervision. We are not responsible for how these sites or apps collect or process your Personal Data. This Policy does not apply to activities on such third-party platforms.
Before accessing or using any third-party website or application, we recommend that you review their privacy policies. We also advise you to exercise caution when providing Personal Data to them.

12. Policy Amendments

When you visit any third-party websites or applications that we recommend, we encourage you to read their privacy policies before deciding to access or use their services. We also suggest exercising caution when sharing any personal data with them.

13. Your rights regarding your personal information

You are entitled to request that we verify the accuracy of Personal Data being collected about you, to rectify any inaccuracies, and to delete all Personal Data that we no longer require. 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 are accessible to you in relation to the Personal Data you provide. You may exercise these rights by sending an email to the address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. If accurate, you are able to access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed at no cost. We 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 the request would be detrimental to the rights and freedoms of another individual, the Company may refuse to comply with the request or limit its capacity to fulfil it.
Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete or inaccurate Personal Data concerning you be corrected, taking into account the purpose for processing.
Right to erasure
The following circumstances apply: (a) Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to continue processing; (c) You object at any time, for reasons specific to your situation, to the processing of Personal Data about yourself that is 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 where processing is necessary (a) to fulfil an obligation required 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 can request that the Company restrict the processing of your Personal Data.
If you request that Personal Data be restricted, it may only be retained with your consent or in order to establish, exercise or defend legal rights, or to protect the rights of another individual, or where there is a substantial 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 to which you are a party, you have the legal right to access your Personal Data that you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to 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 the use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes objections to profiling based on these legitimate interests. If we can establish compelling legitimate grounds for processing your Personal Data, we will not be able to continue processing unless we can demonstrate that they 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 the processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent for us to process Personal Data about you at any time. This will not affect the lawfulness of processing carried out based on your consent prior to withdrawal.
You are entitled 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 in relation to Personal Data processing 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 detailed in this section 13.
We will provide you with the information requested in accordance with your rights under section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and complexity of the request. We will notify you of any extension within one month of receiving your request, along with the reasons.
Unless contrary to the provisions of section 13, the information you request under your rights in section 13 will be provided free of charge. If your request is unfounded, excessive, or repetitive,