Privacy Notice

There are a number of different and equally valid legal bases a company might rely on to collect and process your personal data. These include:

Contractual obligations

In certain circumstances, we need your personal data to enter into, or perform, a contract with you.

For example, if you wish to invest, we will need your personal data to process your application form, and to administer and keep you updated on the investment. If you didn’t provide that data, we wouldn’t be able to process your application.

Legal obligation

We may need to collect and process your data for legal or regulatory reasons.

For example, if you wish to invest, we may use your data to check your identity with a credit reference agency to comply with anti-money laundering rules.

Legitimate interest

We may use your data to pursue our legitimate interests, providing we do this in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. Our legitimate interests are to:

• Run, grow and develop our business
• Ensure a safe environment for our staff and website visitors
• Carry out marketing, market research and business development
• Provide client services; and,
• For internal group administrative purposes.

For example, we will use your name and contact details to fulfil your Wealth Club membership by giving you access to investment research and sending you details of relevant offers, deals, updates and news by post and by email.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.

Consent

In limited circumstances we may collect sensitive information that requires your explicit consent for us to process it. This might happen, for instance, if you applied to invest in a product which includes an insurance element. In this instance, we may need to ask information about your health.

When you request information from us, e.g. when you request a guide or document or express an interest in an investment opportunity, you also become a member of Wealth Club.

Membership benefits include:

• Access to exclusive deals
• Access to investment reports and information
• Preferential terms on some investments
• Investment news and alerts
• Access to free financial guides
• Access to Wealth Club fund manager podcasts, videos and views

There are no costs attached to your membership.

You can stop or cancel it at any time, or request to receive only certain benefits but not others. You can manage your preferences online – see “Your choices over how we use your information”.

We will collect your data:

• When you apply to invest through us
• When you visit our websites and download guides, application forms, reports, or other documents or express an interest in a specific investment or opportunity
• When you request information from us by email, phone, website message or post
• When you contact us by any means about questions, complaints, etc.
• When you respond to any survey we invite you to complete
• When you visit our offices (we have CCTV in operation)
• When you respond to any advert we issue – either online or offline
• When you contact us regarding employment opportunities

• When you request information from us we may collect your name, address, details of the investments or types of investments you are interested in, email address and telephone number.
• We will record whether you are a high net worth individual or sophisticated investor (the Financial Conduct Authority (FCA) requires us to do this before we can provide further information on certain investments).
• We may also ask you for details of your investment knowledge and experience, and your wealth, to allow you to access and invest in certain kinds of deals.
• We may ask you what interests you, so we can send you more relevant information.
• When you visit our website we will collect anonymous data through your web browser, in order to analyse how people interact with and use our website and to show interest-based advertising when you are browsing other sites. See our cookie policy for details.
• When you invest, we will collect further personal details such as date of birth, nationality, National Insurance Number and legal gender (as per providers’ requirements on their application forms and for our anti-money laundering requirements), alongside financial details and bank details.
• We’ll also use your information to prevent fraud and money laundering by running an online check with an anti-money laundering screening tool (which also checks Sanctions and other watchlists), and to meet our regulatory obligations.
• If you invest in our private markets service, we may collect any publicly available information about you, as part of an adverse media screening process
• If you invest using our Nominee Service or Portfolio Management Service, you'll be asked for your bank details so we can a) verify your account details for making payments back out to you and b) so we can match up any payments received by bank transfer. If you wish to pay for an investment via debit card, we do not ourselves process or collect your debit card details. We use the secure services of Fiserv (First Data) which meets PCI DSS requirements, ensuring a safe and secure debit card payment process.
• We will keep a record of your transaction
• If you tell us that you need additional assistance from us (such as large print documents), we will record this.
• When you contact us or we contact you, we record telephone conversations and emails for the purposes of administering your account, training, demonstrating compliance with regulatory requirements, providing evidence in the event of a dispute or in court.
• If you visit our office, your image may be recorded on CCTV.
• When you give us your personal information by phone, email, and via our websites, in writing or otherwise for employment reasons. This includes, but isn’t limited to, information you give us when you apply for a vacancy, are employed by us and when you visit our office premises. The information you give us can include your name, address, email address and other contact information. It can also include your financial information and other personal details such as your National Insurance number and health information. We can also collect information on your employment, training, and education details including your personal information from a recruitment consultant, referees, and job boards as well as from other staff.

Sensitive information

In limited circumstances we may collect sensitive information but only after asking for your explicit consent. For instance, if you apply to invest in a product which includes an insurance element, we may need to ask information about your health, but only after asking for your explicit consent.

• If you ask a question or request information through any medium – online, by telephone or offline – we will use your data to provide a response. We will keep a record of the communication to inform any future exchanges and demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing the best service and understanding how we can improve our service based on your experience.
• If you give us your telephone number we might occasionally call you, for instance, to share time-sensitive information, to update you about current opportunities or in case of problems with your application. We do this on the basis of our legitimate interests in providing the best service and understanding how we can improve our service based on your experience.
• If you invest, we will process your personal details and the financial information you give in the application forms. We will process and keep these records under our legal obligations. We will also send the details you give us, via the application form, to the company that provides the product or service you require. Where you hold investments through our nominee service, we may send your details (i.e. details of you as the beneficial owner) to the company in which you have invested.
• If you request additional support from us, we will use this information to tailor our services and communications to better meet your needs. We will keep a record of this information to ensure ongoing support and to demonstrate our efforts to accommodate your requirements. We do this on the basis of our legal obligations, our contractual obligations to you, and our legitimate interests in providing the best possible service.
• We’ll use your data to protect our business and your investment from fraud and money laundering. This includes carrying out anti-money laundering checks, and, in some cases, adverse media screening checks. We’ll do all of this as part of legal obligations and legitimate interest.
• We’ll ask you to provide bank details (including account name, number and sort code) so we can pay any rebates out due to you, set up a direct debit mandate or make payments out to you: this is on the basis of our contractual obligations to you.
• We will notify you about material changes to our services or terms and conditions, as part of our legal obligations.
• We will use your details and your transactions to respond to any complaints you might make. This is part of our legal obligations. We may also involve our Professional Indemnity Insurers.
• We protect our premises, visitors and staff by operating CCTV at our offices which records images for security. We do this on the basis of our legitimate interest.
• We will send you relevant, personalised communications on deals, offers, services and products for high net worth and sophisticated individuals, to fulfil the benefits of your membership of Wealth Club. We’ll do this on the basis of our legitimate interest.
• We may request your feedback on a product or service via a third party we’ve chosen, or ask for your views on particular investment topics via a survey
• We will identify you when you visit our website, based on our legitimate interest and to make your web journey easier (for instance, so you don’t have to keep confirming you are a high net worth or sophisticated investors).
• We may also collect information about your visit to our website (such as the click path and mouse movement through our websites) as this helps us optimise and improve it. However, none of this information will directly identify you. This is on the basis of our legitimate interest in generating insights that will help us operate our business.

Your information will only be used for the purposes we collected it for (or a closely related purpose, such as record keeping).

We employ a variety of physical and technical measures to keep your personal data safe and prevent unauthorised access to it. Your data is stored on secure computer systems and we control who has access to them (using both physical and electronic means).

We have a data retention policy in place that should ensure we keep data only for as long as is required. For instance, FCA rules require us to keep client records, transaction details and copies of telephone calls for at least five years, whereas CCTV footage is overwritten, typically after 40 days.

We will never sell or trade your personal information. We will share information with our suppliers and data processors and this may include your personal information, but they will only be allowed to use it for a specific purpose and there will be a written agreement which makes sure your information is protected.

For example, when we send our newsletter we use the services of a third-party mailing house to pack and post the communication to you.

We will share personal information with the investment companies in whose products you choose to invest, by sending them your completed application form. Please note, when you apply for an investment, you will also become a client of that third party provider and will be subject to their Privacy Notice, as well as ours. You should check the relevant privacy notice for your chosen third party provider(s).

Where you invest using our nominee service, you will be the beneficial owner of the investment in the applicable company, and will be subject to that company’s Privacy Notice as well as ours. For single company investments, we will send your details to the company in which you have invested, to enable them to meet their regulatory and reporting requirements and to issue EIS3 certificates where applicable.

We will also share your information when we are required to do so by law or by a regulator or governmental authority (for example HMRC, the FCA or the Financial Ombudsman Service). We may share it with our professional indemnity insurers, where you make a complaint against us.

Some of our suppliers and data processors may be outside the UK or Europe; see the section below for details.

We currently use the following subcontractors to process your personal data and have agreements with them to govern how they may use the data:

• Amazon Web Services (AWS) – the Wealth Club database is hosted on a secure AWS server, based in Dublin.
• Amazon Simple Storage Service (S3) – used for storage of scanned application forms.
• Box – to send completed applications to the investment product providers.
• Cloudflare – to protect our business and our website users from denial of service attacks and to protect us from hacking attempts.
• Clover (formerly Fiserv and First Data) – to allow you to make secure debit card payment via MSP and PSP services. The service meets PCI DSS requirements, ensuring a safe and secure debit card payment process.
• Cognito Forms – to allow users to express interest in and make reservations for investments, or complete surveys on our website.
• Comply Advantage – the screening tool we use to perform adverse media and sanctions checks for certain offers.
• Currencies Direct – to allow you to make payment for certain deals in a currency other than sterling.
• Fastpay – our Direct Debit service provider.
• Lexis Nexis – the screening tool we use to perform anti-money laundering and sanctions checks and bank account verification.
• Mailchimp – the email service we use to send and manage emails.
• Mailing Guy – the mailing houses we use to send out our newsletters and updates.
• ResponseIQ – to provide our request a callback / schedule a callback functionality.
• Seccl Custody – to provide our portfolio management service. Seccl acts both as a data processor on behalf of us, as well as a data controller for its own purposes. Full details of how Seccl process personal data can be found at: https://seccl.tech/privacy/
• Sumo – to provide our 'ask a question' prompts on our website.
• Momentive (SurveyMonkey) – to carry out surveys.
• Textlocal – to send SMS notification codes to help users log in.
• TrueLayer – to accept and process payments, or to collect your bank details, via open banking. TrueLayer acts both as a data processor for behalf of us in processing these, as well as a data controller to process payment data for its own purposes. Full details of how TrueLayer process personal data can be found at: https://truelayer.com/legal/privacy
• Trustpilot – to send review invitations to allow investors to review our service.
• Wealth Club Asset Management and Wealth Club Nominees Ltd – where you use services provided by these subsidiary companies
• Xero – our accounting software.
• Zapier – to create connections between other applications, for instance between Cognito Forms and Mailchimp.

We also use the services of Google Analytics to see how users interact with and use our website. The data is anonymised and cannot be used to identify you.

Our website uses Mouseflow, a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback campaigns, and similar features/functionality. Mouseflow may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser. If you’d like to opt-out, you can do so at https://mouseflow.com/opt-out.

If in future the ownership of Wealth Club changes then your data may be shared with the new owners.

When you visit or interact with our sites, services, applications, or messaging, we or our authorised service providers use cookies and other similar features to help provide you with a better, faster, and safer experience and to enhance certain functionality (such as recognising you have visited the site before and remembering your settings). You can choose to set your web browser to refuse cookies or to alert you when cookies are being sent. However, if you refuse cookies, you may not be able to use the full functionality of the site. See our cookie policy for more information.

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels). We must always comply with your request.
• In certain situations, you have the right to request that your data be deleted (the right to be forgotten).

If you would like further information on your rights or wish to exercise them, please write to us or email [email protected] with details of your request.

If we decline to satisfy your request we will explain why.

If you believe that any information we hold on you is incorrect or incomplete, please contact us.

Your right to withdraw consent

Whenever you have given us your consent to process your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In most cases, where we process your personal data on the basis of our legitimate interest, you can ask us to stop (your right to object). We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

Please keep in mind there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, if the information no longer exists or there is an exception which applies to your request).

You have choices about how we use your personal information to communicate with you and how we fulfil your membership of Wealth Club.

You can change how we contact you, how often and about what. You can pause or cancel your membership as well as tell us what you’d like to hear about through our online preference centre.

You can set and change your preferences at any time and as often as you like by visiting our online preference centre or by contacting us. You can also object to us processing your data.

Please note: if you cancel your Wealth Club membership you will stop receiving offers and deals from us, but if you’ve invested we will still send you information about your investments (as this is a contractual obligation).

If you cancel your membership, or if you unsubscribe from emails, your name, address and email address will go onto a suppression list so we can comply with your requirements. The suppression list will be kept for the life of the business.

Except as set out below, we normally only store personal information within the UK or the European Economic Area (EEA). The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

If one of our suppliers or subcontractors needs to transfer personal information of Wealth Club members outside the UK or EEA we will take steps to make sure adequate levels of privacy protection, in line with UK data protection law, are in place. For example, we use standard contractual clauses with third parties, so that your information is protected to the same standards as it is in the UK or European Economic Area.

Please contact us if you wish to receive further details of the safeguards in place to protect your data using international organisations.

Suppliers we use based outside the UK or the EEA include:

• Box – based in the US
• Cognito Forms – based in the US
• Mailchimp – based in the US
• Momentive (SurveyMonkey) – based in the US
• Sumo – based in the US
• Xero – based in New Zealand. Xero relies on a combination of measures to ensure compliance with EU data rules, including Model Clauses.
• Zapier – based in the US

If you believe your data protection or privacy rights have been infringed, or are not happy with how we have treated your data and your rights, you should contact the UK Information Commissioner’s Office, the UK regulator for data protection. Details of how to do this can be found at www.ico.org.uk.

We may update this Notice at any time. When we do, we will revise the date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping protect the personal information we collect.

You can contact us about data protection at 20 Richmond Hill, Bristol BS8 1BA, by email to [email protected] and by phone on 0117 929 0511.