Privacy Policy
Last update: 24.03.2026
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 Promenade Earnd (the "Website").
We uphold these principles:
To be transparent about how we process and collect your personal information:
We want you to make informed decisions about how we use and process your Personal Data. That's why we created this website. We use various methods to give you clear information about Personal Data processing.
If we think you need specific details, we'll provide them at the right time.
We're happy to answer your questions and explain any legal limits affecting your data. Contact us by email at: info@promenade-earnd.com
Your 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 requirements, and carrying out 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 protect your rights regarding your Personal Data, you can use important safeguarding tools:
To help you exercise your rights, we have substantial resources available. Contact us anytime to request information about 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.
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 provides full details.
1. The Scope?
This policy outlines 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 relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or recognised through a combination of additional 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 years of age. We do not knowingly collect or solicit information from individuals under 18, nor do we knowingly permit them to use our services. If we become aware of any information about children, we will delete it as quickly as possible.
2. What Personal Data Do We Hold About You?
When you access our service, channels, or website, we collect your Personal Data. We may ask you to provide Personal Data directly in some cases. In other instances, we gather your Personal Data by analysing how you use our Services or channels, or by receiving information from third-party partners.
You're not required to share personal information with the company, nor are there any consequences for not doing so.
However, you're not required to provide us with any personal data. In certain circumstances, if you choose not to supply personal data, we may be unable to offer our Services or allow you to access 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, traffic data (including IP address, access date, access time, and language used), software crash logs, browser type, and device information. This data 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 trading.
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 use 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 reasons, including when you submit personal information through our website so we can transfer it to 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 legal claims.
- Processing must comply with legal requirements.
Contact us by email for details about how we process your information to protect our 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 parties at your request for digital trading access
If you ask us to, we may collect Personal Data from you to pass on to third-party companies.
You've consented to your Personal Data being processed for one or more of the stated reasons.
2. To answer your requests, questions or concerns
We need your Personal Data to respond to any questions you may 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 law, including administrative, judicial, and regulatory requirements.
To meet legal requirements, we need to process your information.
4. To enhance Our Services
We may use Your Personal Data to improve Our Services. This includes, for example, crash reports and malfunction data we collect related 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
The Company or a third party has a legitimate need to process this information.
6. To perform and manage actions that support Our Services
This includes back-office functions, business development, strategic decision-making, oversight mechanisms, and related activities.
We need to process your 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.
The Company or a third party's legitimate interests require the processing of this data.
To protect our assets, rights, and interests—as well as those of third parties—we have developed
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 policies.
The Company or a third party's legitimate interests require the processing of your information.
6. Transferring Your Personal Data to Third Parties
The Company may share your Personal Data with third-party service providers, such as hosting and storage providers, and with IP address information analysts to improve user experience.
You can request that we share your Personal Data with third-party trading platforms. When you do, we will provide your Personal Data to those platforms, whose 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 help enhance and improve the products and services we offer.
If required to protect the rights of third parties or safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may additionally share Personal Data about you with potential investors, buyers, lenders to the Company, or other group entities in connection with any transaction (including the transfer or sale of Company assets or group company assets) or in the event of a merger, restructuring, consolidation, or bankruptcy involving the Company or any other group business.
7. Third-Party Cookies and Services
Third-party services, such as advertising and analytics providers, may be used on our website. These companies may also use cookies and similar technologies.
Cookies are small text files placed on your device when you visit our website. We use cookies to understand your preferences and browsing behaviour, improve your experience, remember your choices, 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 that expire when you close your browser. Other cookies are persistent. Persistent cookies remain on your device after you close your browser and help us recognise you as a returning visitor, allowing you to return to the website more easily.
Types of Cookies:
We may use them according to their intended purpose.
The type of cookie
Cookies are essential for this website to function
Scope
These cookies are essential for accessing the features you've requested and navigating 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 you're logged in to the site. They're deleted 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 erased when you close your web browser (session cookies).
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and improve your experience on our site. They also enable 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, while others remain indefinitely.
Cookies are blocked or removed
To block or remove cookies, adjust your browser 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 features or the entire Website may not function 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 as described in this Policy, or for longer periods as permitted by applicable law, regulations, and 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 retained Personal Data to ensure it's no longer required.
9. Transfers of personal information to third countries or international organisations
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country — meaning a country outside your place of residence — or to international organizations). The Company takes all necessary steps to protect your Personal Data and ensure that users 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 for 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 pursuant to 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 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 used to protect your Personal Data when transferred to third-party countries or international organisations. Please contact info@wealthwaydigital.uk for more information.
10. Security of Your Personal Data
We have implemented appropriate organisational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will remain error-free. 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, Personal Data disclosed due to transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
If required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. We cannot control how third parties secure your Personal Data in these situations.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of Personal Data you send to us online.
11. Hyperlinks to third-party websites
The website contains links to third-party sites and applications that operate independently of the Company. We do not oversee these platforms and are not responsible for how they collect or process your Personal Data. This Policy does not apply to any actions you take through these external sites or apps.
Before accessing or using any third-party website or app, we recommend 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 reading their privacy policies before deciding to access or use them. We also suggest reviewing what Personal Data you choose to share with them.
13. Your rights regarding your personal information
You are entitled to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete Personal Data that we no longer need. You may also restrict how we process your personal information.
If you are resident in the EEA, please refer to this page:
These rights apply to the information you provide relating to your Personal Data. You can exercise these rights by emailing the address below.
Access rights
We can verify the accuracy of Personal Data we process about you. If accurate, you can access your Personal Data.
We will provide an electronic copy of your Personal Data at no cost. We may charge a reasonable fee for additional copies. The data will be made available electronically upon request.
Your right to access Personal Data cannot override the rights and freedoms of others. If a request would harm another person's rights and freedoms, we may refuse it or limit our response.
Right to rectification
We can correct inaccurate Personal Data. You can request that incomplete Personal Data about you be corrected, taking into account the purpose of processing.
Right to erasure
The following reasons apply: (a) Personal Data are no longer needed for the purpose they were collected for; (b) You withdraw consent and there is no legal basis to continue processing; (c) You object at any time, based on a reason specific to your situation, to processing of your Personal Data based on legitimate interests pursued by us or a third party; (d) Personal Data are processed unlawfully; or (f) 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 are concerned about the accuracy of your Personal Data, you can ask us to limit how we process it.
If you request a restriction, we may only keep your Personal Data if you consent, or to establish, exercise or defend legal rights, or to protect another person's rights, or for a reason of significant public interest 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 part of, you have the right to obtain and reuse your Personal Data.
You can request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. This right does not interfere with the rights or freedoms of others.
Right to object
You have the right at any time to object to processing of your Personal Data based on legitimate interests pursued by us 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 stop unless you show your rights, freedoms or interests outweigh ours, or the processing is necessary to establish, exercise or defend 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 can withdraw your consent for us to process your Personal Data at any time. This does not affect the lawfulness of processing that occurred before you withdrew your consent.
You are entitled to lodge a complaint with your supervisory authority.
You may lodge a complaint with the supervisory authority in your Member State responsible for protecting individuals' fundamental rights in relation to Personal Data processing within the EU.
EU and Member State laws may limit your rights regarding Personal Data, as detailed in this section.
We will provide the information you request under your rights within one month of receiving your request. We may extend this to two months if necessary, depending on the complexity and volume of requests. We will notify you of any extension within one month, including the reasons.
We will provide the information you request under your rights at no cost, unless contrary to this section. If a request is unfounded, excessive or repetitive, we may charge a reasonable fee to cover our administrative costs. We may also decline to act.
If we doubt your identity, we may ask you for further information to verify it.