Karvyn Markholm

Privacy Policy

Last update: 25.05.2026

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 Karvyn Markholm (the "Website").
These principles will be upheld:

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

We want to help you make informed decisions about how your Personal Data is used and processed. That's why we created this website. We use various methods to give you clear information about Personal Data handling.
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 you'd like to know about how the law affects your data. You can contact us by email at: info@karvyn-markholm.com

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

We process your Personal Data to deliver our website and Services, which include connecting you with third-party trading platforms, improving our site, protecting our rights and interests, maintaining our Services, meeting legal and regulatory requirements, and supporting our administrative and business operations. 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 important tools that protect your rights regarding your personal data:

To help you exercise your rights, we have substantial resources at your disposal. Contact us at any time to request access to your personal data. We can modify or delete it, stop processing it for specific purposes or general purposes, transfer it to you or a third party, and accommodate your requests accordingly.

Protect Your Personal Data:

While we cannot guarantee complete security of your personal data, we can assure you that we continuously employ a range of methods and techniques to help protect it.
Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of personal data we collect from individuals and how we process, share, and protect it.
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.
We define "processing" as any activity involving the use or collection of personal data, including its management, organisation, and storage.
Our services are intended for general audiences and are not designed for anyone under 18 years old. We do not knowingly collect information from or allow anyone under 18 to use our services. If we become aware of any information about children, 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 ask for your Personal Data directly in some cases, and in others we gather it by analysing how you use our Services or channels, or by receiving information from our third-party partners.

There is no requirement to disclose personal information to the company or face any 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, 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 gather the following personal information:

This includes information about your online activity log, traffic data (including your IP address, access date, access time, and browser language), software crash logs, browser type, and device information. The information collected is not personally identifiable and cannot be used to identify you.
Personal Data We Receive from You: any personal data you voluntarily provide 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 trades.

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 may process your Personal Data are:

  • You've consented to us processing your Personal Data for one or more reasons. This applies when you submit personal information through the 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 their legitimate interests, such as improving our Services or defending legal claims.
  • Processing must comply with legal requirements.

Contact us by email for more details about the processing we carry out to protect our legitimate interests.
Below is a list of the reasons and legal grounds we may use your information for. Personal Data.

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 have provided consent for your Personal Data to be processed for one or more of the specified reasons.

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

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

We process your personal data to comply with legal, administrative, and judicial obligations.

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, including any crash reports or malfunction data we collect in relation to the Services.

The Company or a third party may need to process personal data based on legitimate interests.

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 carry out and manage actions required to deliver Our Services
This includes back-office functions, business development, strategic planning, and oversight processes.

We may need to process data based on 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 has a legitimate interest in processing this information.

To safeguard our assets, rights and interests as well as those of third parties, we process Personal Data in accordance with applicable laws, regulations and agreements. This processing enables us to establish and defend legal claims, and to protect our rights, interests and assets, or those of third parties, in compliance with any relevant conditions, terms or policies.

The Company or a third party may need to process personal data to pursue legitimate interests.

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, as well as to analyse user experiences and IP address information.
You can request that we share specific Personal Data about you with third-party trading platforms. When you do, we'll provide your Personal Data to those platforms in accordance with their 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 the products and services we offer our customers.
If necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or other group companies in connection with any transaction (including the transfer or sale of Company assets or group company assets) or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other group company.

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 or similar technologies.
Cookies are small text files placed on your device when you visit or access our website. We use cookies to gather information about your preferences and browsing habits to improve your user experience, remember your preferences, and personalise the products and services we offer. Cookies also help us with statistics and analytics.
We use two main types of cookies. Session cookies are temporary and downloaded to your device for a short period—they're deleted when you close your browser. Persistent cookies remain on your device for a longer 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 your next visit.

Types of Cookies:

They may be used by us according to their purpose:

The type of cookie

Cookies are essential

Scope

These cookies are necessary for you to access the features you've requested and navigate our website. They 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 around the website, use its features, and return to pages you've visited before.

Additional Information

Cookies collect personal data, including your username and last login date, to verify 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 allow us to recognize you when 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

Cookies help us gather performance data and analyse how our website is being used, so we can continue to improve it.

Additional Information

Cookies store anonymous data that isn't linked to any identifiable person. They can be removed when you close your browser. Some cookies remain active indefinitely.

Cookies are blocked or removed
To prevent or remove cookies, adjust your browser settings. Below are links to help you with the most popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

However, be aware that certain Website functions and features 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 law, regulations, and applicable 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 needed.

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 (outside your country of residence) or to international organisations. 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 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 under 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 adopted by the EU Commission under Article 46(2)(c) of the GDPR. You can view the EU Commission's adopted 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. Email 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 against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that your Personal Data will remain secure without error. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data, including (but not limited to) disclosure due to transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
Where required by law or other obligations beyond our control, we may be required to disclose Personal Data about you to third parties, such as public authorities. We cannot control how third parties secure your Personal Data in these situations.
Data transmitted over the internet cannot be completely secure. The Company cannot guarantee the security of Personal Data you send to us through the internet.

11. Links to third-party websites

The website contains links to third-party sites and applications that operate independently of the Company. We do not supervise these external platforms and are not responsible for how they collect or process your Personal Data. This Policy does not apply to any activities conducted through such sites or apps.
Before accessing or using any third-party website or app, we recommend that you review their privacy policies. We also suggest exercising caution when 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 accessing or using them. We also suggest reviewing what Personal Data you provide to them.

Your rights regarding your personal information

You are entitled to request that we verify the accuracy of your Personal Data, rectify any inaccuracies, and delete Personal Data that we no longer require. You may also restrict how we process your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide regarding your Personal Data. You may exercise these rights by sending an email to the address below.
Right to access
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 and may charge a reasonable fee for additional copies. The data will be made available electronically upon request.
Your right to access Personal Data must not conflict with the rights and freedoms of others. If the request could harm another person's rights and freedoms, the Company may refuse the request or limit what it can provide.
Right to rectification
You are entitled to request that the Company rectify any inaccurate or incomplete Personal Data concerning you, taking into account the reason for processing.
Right to erasure
The following reasons apply: (a) Personal Data are no longer needed for the purpose they were collected for or processed; (b) You withdraw consent and there is no other legal basis for processing; (c) You object at any time, based on your specific circumstances, to processing of Personal Data about you that relies on legitimate interests pursued by us or a third party; (d) Personal Data are being 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 required by European Union law 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 restrict its processing.
If you request that Personal Data be restricted, it may only be kept with your consent or to establish, exercise or defend legal rights, or to protect another person's rights, 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 consent or a contract you are party to, you have the legal right to review 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 your right to erasure. The right to transfer data does not affect anyone else's rights or freedoms.
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 objections to profiling based on these legitimate interests. If we can demonstrate compelling legitimate grounds for processing, we may continue unless you prove those grounds are outweighed by your rights, freedoms, interests or legal needs.
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 does not affect the lawfulness of processing carried out before your withdrawal.
You have the right to lodge a complaint with the supervisory authority in your country.
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 European Union.
EU and Member State laws may limit your rights regarding Personal Data, as described in this section.
We will provide the information you request under these rights within one month of receiving your request. We may extend this period by up to two months if necessary, depending on the complexity and volume of requests. We will notify you of any extension and the reasons within one month of your request.
Unless otherwise provided by law, the information you request will be provided free of charge. If your request is unfounded, 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 ask for further information to verify it.