Privacy Policy

Wealt is the trading name of Wealt Group Limited, which is registered in England and Wales, company number 13929507, and with registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK.

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You can reach us by:

• Post: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK.
• Email: hello@wealt.co
• Website: https://wealt.co

Changing Your Preferences

If you’d like to change your web, contact or marketing preferences, you can do so at any time. Simply contact us at hello@wealt.co to request the necessary amendments. You can also manage push notification preferences from your device settings at any time.

How We Do Business

Wealt Group Limited (we, our, us) is committed to upholding and maintaining your personal rights. We operate our business in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the EU General Data Protection Regulation, and observe your rights to change or withdraw your opt-in options at any time. As part of our ongoing commitment to uphold your rights, Wealt Group Limited will also extend advice on how you can issue formal complaints to relevant authorities, such as the Information Commissioner’s Office (ICO).

Who Our Privacy Policy Applies To

This privacy policy has been developed to inform users of Wealt Group Limited how we use their data. Wealt is a seamless and secure platform designed to help you see all your bankable and non-bankable assets in one place and make empowered decisions, and we need to process the data of individuals to offer our products and/or services. Our privacy policy applies to any and all individuals registered with us as a user, customer, administrator or in any other capacity, whether you use our website or our mobile application.

What Information This Policy Applies To

There is a lawful basis for processing your data, and this section of our privacy policy outlines how this applies to the personal information you provide us with or allow us to collect.

The information this policy applies to includes information that you:

• Provide as part of any registration process (name, email address, phone number, date of birth)
• Provide when you sign in with a third-party identity provider (Google or Apple)
• Provide as part of identity verification (see “Identity Verification” below)
• Provide when adding assets, investments or transactions to your portfolio
• Provide in the form of numerical data, metadata, or communications
• Give us as part of our ongoing relationship

This policy also applies to information that we:

• Collect relating to how you interact with our website and mobile application (see “Analytics & Diagnostics” below)
• Collect from your device, such as device model, operating system version, app version, language, push notification tokens and app-instance identifiers
• Must process to complete purchases and other transactions

Identity Verification & Biometric Data

To comply with our legal obligations (including anti-money-laundering and know-your-customer regulations) we verify the identity of investors before they can access certain services. Identity verification is carried out by our verification partner Sum and Substance Ltd (Sumsub), acting as our processor.

During verification, and with your explicit consent, the following data is collected through the app and processed by Sumsub on our behalf:

• Photographs of your identity document (e.g. passport, driving licence)
• A live selfie / facial scan, from which biometric identifiers may be derived to match your face against your document
• Your approximate geolocation at the time of verification, used to help confirm your identity and prevent fraud

Biometric data is special category data. We process it only for identity verification and fraud prevention, on the basis of your explicit consent and our legal obligations. Verification records are retained for as long as required by applicable anti-money-laundering law after the end of our relationship with you.

Device biometrics (Face ID / Touch ID / fingerprint): if you enable biometric unlock in the app, the biometric check is performed entirely on your device by its operating system. We never receive, store or have access to your device biometric data — we only receive the yes/no result of the check.

Sensitive Data

Other than the biometric data described in “Identity Verification & Biometric Data” above, Wealt Group Limited does not collect any sensitive data about you. Sensitive data refers to (but is not limited to) information about your race or ethnic background, religious or political affiliations, trade union affiliations, sexual orientation, criminal background, or health background.

Mobile Application Permissions

The Wealt mobile app may request the following device permissions. Each is optional and used only for the stated purpose:

• Camera and photo library — to capture or upload identity documents during verification, and to share images in support conversations
• Microphone — to record audio within support conversations
• Location (while using the app) — solely to support identity verification, as described above
• Notifications — to send you push notifications about your account and, where you have opted in, marketing communications
• Face ID / Touch ID — to let you unlock the app; processed on-device only

You can withdraw any of these permissions at any time in your device settings.

Analytics & Diagnostics

We use a small number of carefully selected service providers, acting as our processors, to understand how our products are used, to communicate with you and to keep the app reliable:

• Google Firebase / Google Analytics (Google LLC) — usage analytics (e.g. screens viewed, in-app events) and delivery of push notifications
• CleverTap (CleverTap Inc.) — customer engagement: user profiles (name, email, phone number, date of birth), in-app behaviour events, and push notification delivery and preferences
• Sentry (Functional Software, Inc.) — crash reporting and application diagnostics, including device model, OS version and technical logs relating to errors
• Intercom (Intercom Inc.) — in-app customer support chat, including your contact details and the content of your conversations with us
• Expo (650 Industries, Inc.) — app performance metrics (e.g. app start-up time) and delivery of app updates

These providers process data on our instructions and are not permitted to use your personal data for their own purposes.

Consent

When you submit personal data on our website or in our mobile application, you are giving us your consent that we can use that data in line with our privacy policy. Where we rely on consent (for example, marketing communications or biometric identity verification), we will ask for it explicitly and you may withdraw it at any time.

Opting-out

After giving us your consent, you are free to amend your consent or withdraw your consent at any time. You have the right to object to the processing of your data. To opt-out, change your preferences or revoke your consent, simply contact us by emailing dpo@wealt.co. You can opt out of push notifications in your device settings, and out of marketing emails via the unsubscribe link in any marketing email.

Data Processing & Storage

We store your data primarily in the UK. Some of our service providers listed in this policy operate outside the UK and the European Economic Area, including in the United States. Where data is transferred internationally, we ensure an adequate level of protection through appropriate safeguards such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses, or an applicable adequacy decision.

We retain your data as follows, unless a longer period is required by law:

• Account and profile data — for as long as your account is active, and for up to [X months] after your account is closed
• Identity verification (KYC) records — for at least five years after the end of our relationship with you, as required by anti-money-laundering law
• Transactions, payments and orders — for a period of up to seven years
• Analytics and diagnostics data — for up to [X months] from collection

We may process your data based on more than one legal ground. Circumstances under which we may be required to process your data under more than one legal ground include:

Marketing & Communications

We may send you marketing communications (including email and push notifications) if you have given us your contact details and opted in to marketing communications. You can opt out of these marketing communications and manage your preferences at any time.

Our Company Obligations

As a data controller, Wealt Group Limited is legally responsible for the data you provide us with. In honouring that responsibility, we pledge to uphold our commitments under the UK GDPR and the Data Protection Act 2018.

We will only ever use your data:

• In ways that are both fair and legal
• As described within this policy
• In ways that are necessary for the purposes described

We take all necessary technical and organisational precautions to secure the personal data we collect, process and store.

We may occasionally use the data you provide us with for marketing, relationship management or account management activities. These activities are designed to ensure you have adequate information about other products and/or services we offer that we have reason to believe you may be interested in. You have the right to opt out of these activities at any time.

Third-Parties

Wealt Group Limited never shares your personal data with third parties unless those parties have been explicitly mentioned within this privacy policy or we are required to do so by law. The processors we currently use are listed in the “Identity Verification & Biometric Data” and “Analytics & Diagnostics” sections above.

Our Security

If a personal data breach occurs, we will notify the Information Commissioner’s Office without undue delay and, where feasible, within 72 hours of becoming aware of it. Where the breach is likely to result in a high risk to your rights and freedoms, we will also inform you without undue delay.

Legitimate Interests

As permitted under the Data Protection Act 2018, Wealt Group Limited observes the right to share selected information with third parties that use data for non-marketing purposes. This could include (but is not limited to) organisations that provide credit assessments, identification services and fraud prevention activities.

Contact Us

We are committed to upholding your rights. If you have any questions, comments or concerns about this privacy policy or wish to exercise your rights in relation to your personal data (including access, rectification, erasure, restriction, objection and portability), please contact us at dpo@wealt.co. You also have the right to lodge a complaint with the Information Commissioner’s Office (ico.org.uk).

We will process any request within one month. Subject Access Requests are normally performed free of charge, but we may need to charge individuals for excessive or unreasonable data requests.