Your personal data is very important to us. We will endeavour to take care to protect this information. We would like to highlight below a few matters relating to your information that you should be aware of.
About Us Our Privacy Notice gives you detailed information on when and why we collect your personal data, how we use it and how we keep it secure. WealthKernel Limited (“WealthKernel”) is registered in England and Wales with company number 09686970. Our registered office address is at 41 Luke St, London, UK, EC2A 4DP. We are also registered with the UK Information Commissioner’s Office with registration number ZA180129.
In some circumstances, WealthKernel is the data controller of your personal data. This could be your name, contact details, address or any other information that can be linked to you.
If you have any questions regarding this notice, or how we process your personal data, or if you would like to exercise any of your rights under data protection law, please contact us by emailing firstname.lastname@example.org.
Who does this apply to? This privacy notice is for visitors to our website, clients using our services, and any prospective clients making enquiries via our website and other media. We have split up this notice into sections so that you can easily find the sections which apply to you.
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When you contact us If you get in touch with us you may provide us with personal data. For example, if you use our contact form, we ask for your name, email address, website URL, which modules and countries you are interested in. Only information that is needed to deal with your enquiry will be shared internally or with selected third parties. We will use the information you provide to deal with your enquiry and for no other purpose.
When you use our services By deciding to use our services (as described in the “Our service” section of the Terms and Conditions), you are choosing to provide us with personal data about yourself. We will use this for the purposes described in the “Our service”, “Do we handle your money and investments” and “Anti Money Laundering” sections of our Terms and Conditions. When using most of our platforms, we collect information such as name and surname, age, nationality, National Insurance or social security number, tax residency status, email address, and address. When using the JISA platform for investments for the benefit of a minor, we would collect the above information on the registered contact, and then also information on the minor such as name and surname, age, nationality, and address.
Children Under 13 We process information on children under the age of 13 when provided to us by the registered contact for use on the JISA platform.
AML and KYC In conducting background screening and due diligence checks we may also request identification documents and will collect information about you from other sources, including trusted approved suppliers and publicly available sources. This may include information considered sensitive under data protection law, which will be afforded the highest level of security.
Marketing When you agree to receive marketing material from us or third parties, we collect your name, email address and preferences, so that we may provide you with the relevant marketing materials.
WHY WE COLLECT YOUR INFORMATION AND HOW WE USE IT The information we hold on you will be used in a number of ways. Under the UK Data Protection Act, we can only use your personal data if we have a legal basis for doing so. The legal basis upon which we rely to process your personal data will be one of the following:
Performance of a contract with you
For our legitimate interests (which may include those of a third party)
Compliance with a legal obligation
Where we have indicated that we use consent as the legal basis to process your personal data, you have the right to withdraw consent at any time. We shall then delete your personal data unless it is linked to another process where we have a lawful basis to process it.
The list below sets out more specifically how we use your personal data, the purpose of the processing and the legal basis upon which we rely for the processing. Provision of services If you are a new customer we will collect information about you including contact details, financial information and information about your household and relationships where relevant for the management of your finances. In providing services for you and in managing our relationship with you we will process contact details, financial information and records of our interactions with you. Legal Basis – Performance of Contract
Due diligence We carry out background screening and due diligence processes (also known as KYC/AML), including anti-money laundering, anti-bribery and corruption, credit and anti fraud checks, to comply with various laws and regulations, build effective customer relationships and give assurance to our partners.
Legal Basis – Legal Obligation – We have an obligation to comply with relevant legislation.
Legal Basis – Legitimate Interest – It is in our interest to safeguard our business and reputation and those of our customers.
Responding to queries When you contact us with queries relating to our products or services we offer, either as a client or prospective client, including our website ‘Contact Us’ page, we will process the query, your contact details and associated notes. Legal Basis – Legitimate Interest – It is in our interest to administer the arrangements that we have with you under our Terms and Conditions and to provide customer service and support functions including those made available on our website and over the telephone
Marketing of our own products If we wish to communicate with you about our own products/services, we shall give you the opportunity to opt out of these types of communications from us.
Legal Basis – Legitimate Interest – It is in our interest to market our products and services to you
Marketing for our business partners We would like to tell you about the products and services of the business partners we work with by means of marketing communication (by telephone, email or post). When you become a client of ours, you will have the option to consent, or opt in to receiving such communications.
In addition, we would like to share your name and contact details (in particular your telephone number, email and/or postal address) with our business partners so that they can contact you directly to tell you about their products and services. These types of communications will also only be made with your prior consent.
Legal Basis – Consent
Analysis We sometimes anonymise and/or aggregate personal data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor our business and our service offerings, to conduct risk assessment and to analyse costs and charges. We do this in such a way as to ensure that you are not identified or identifiable from it, in order to use it for the above purposes.
Legal Basis – Legitimate Interest – It is in our interest to conduct market research and analysis including developing statistics.
Monitoring We will monitor and record telephone calls and monitor email communications with you when necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business and to prevent or detect crime. We will also do this for the purpose of quality control, security and training, resolving complaints and/or to evidence the nature and contents of such conversations.
Legal Basis – Legal obligation – We have an obligation to comply with relevant legislation.
Legal Basis – Legitimate Interest – It is in our interest to administer the arrangements that we have with you under our Terms and Conditions and to provide customer service and support functions including those made available on our website and over the telephone;
Updating you about changes at our organisation We may email you about any changes to this policy and others via email.
Legal Basis – Legitimate Interest – It is in our interest to keep our clients informed of any changes to our policies.
Responding to data protection rights When we are processing your request for information or when you exercise your rights against us under data protection law.
Legal Basis – Legal Obligation
HOW WE MANAGE AND SHARE YOUR INFORMATION We will never share, sell, rent or trade your personal data to any third parties for marketing purposes without your prior consent. We will ask for your consent to share personal data with our marketing partners.
Who we share your information with We may share personal data within the WealthKernel group of companies, which may include the transfer of information across international borders.
We engage a variety of third parties to provide services to WealthKernel. These services include business processing, obtaining compliance or regulatory advice (such advice usually being obtained from professional advisors), due diligence checks and other services.
We may disclose your personal data in response to a court order, to the FCA in accordance with our duties as an FCA authorised firm, to our legal and professional advisors, to our service providers, to actual or prospective purchasers of our business or assets and to law enforcement or other government agencies, in each case subject to our obligations under applicable data protection laws.
We will also share your personal data with your Introducer and the Custodian as described in the “Do We Handle Your Money And Investments?” section of our Terms and Conditions should this be necessary to administer your relationship with us as part of our contract with you. We may also share your personal data with replacement asset managers.
International transfers Your information may be shared within the European Economic Area (EEA). In particular, transfers will be made outside the UK and the EEA. We may also transfer your personal data to countries or territories which do not provide the same level of protection as those in your country of residence. In those cases, steps will be taken to protect your personal data in the country of import, as required by applicable data protection laws to which we are subject. In such instances, we will put in place measures to protect such transfers and your data protection rights, such as the EU Standard Contractual Clauses (also known as EU SCCs). If you would like to know more about our international transfers, please use the contact information provided at the start of this document.
HOW WE LOOK AFTER YOUR INFORMATION We only use established suppliers and vendors who meet the highest standards of information security and privacy standards. We vet suppliers which store and transfer your data and are sure your information is adequately protected. We use a variety of technical and organisational methods, including suitable access controls and encryption of your data in transit and at rest, to keep your data safe. When we work with third parties we use contractual measures to establish the appropriate and secure handling of your personal data.
HOW LONG WE KEEP YOUR INFORMATION We will keep your personal data only for as long as we need it to fulfil the purposes for which it was collected and to comply with legal and/or regulatory requirements. The criteria we use to determine data retention periods for personal data include the following:
Retention in case of queries. We will retain your personal data in case of queries from you about our provision of services to you until your query has been dealt with, and a short period after that, in order to ensure that any follow up questions can be appropriately handled.
Retention in case of claims. We will retain some personal data for the period in which you might bring claims against us in connection with our Terms and Conditions, including any legal claims or court cases.
Retention in accordance with legal and regulatory requirements. We will retain your personal data after the periods described above only as necessary to comply with our regulatory compliance obligations, or statutory requirements for data retention.
YOUR RIGHTS You have various rights under data protection law, which we have described below. Please note that they may not always be applicable, depending on the circumstances. If you wish to exercise any of these rights please contact us email@example.com. You will not be required to pay any fee for exercising your rights.
You have the right to obtain copies of, or access to, your personal and financial information which we hold as data controller, subject to certain exemptions and restrictions.
You have the right to seek the rectification of inaccurate personal data without undue delay and to have incomplete personal data completed in certain circumstances.
You have the right to have personal data erased without undue delay in certain circumstances (also known as the “right to be forgotten”). This right is not absolute – it applies only in particular circumstances and where it does not apply any request for erasure will be rejected.
You have the right to withdraw your consent for any processing which was based on consent at any time. This will not invalidate any of the processing that has previously taken place.
You have the right to object to processing of your personal data – this right allows individuals in certain circumstances to object to processing based on legitimate interests, including profiling based on legitimate interests; direct marketing; and processing for purposes of statistics.
You have the right to restrict the processing of your personal data may apply if you contest the accuracy of your personal data (which is proven to be correct); when the processing is unlawful and you request that use of the personal data is restricted and where you do not want erasure instead; or when we no longer need to process the personal data but you require the personal data to be retained in case of future legal claims.
You have the right to data portability where the personal data is processed by us based on consent, a contract, or using automated means (as relevant). This right allows individuals to obtain and reuse their personal data for their own purposes across different services without hindrance to usability.
You have rights relating to any automated decision making, including profiling, if this has a legal or other significant effect on you. In certain circumstances you may request human intervention or an explanation of how the decisions taken.
How to complain If you have any concerns about our use of your personal data, you can make a complaint to us at our details listed above in the ‘About Us’ section.
Without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the data protection supervisory authority in the UK. You may do this if you consider that we have infringed the applicable data protection law. In the UK, the supervisory authority who is empowered to investigate whether we are complying with the data protection law is called the Information Commissioner’s Office: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
UPDATES OR CHANGES TO THIS PRIVACY NOTICE This policy was last updated on 5th April 2022. We may review and update it periodically as any of our processing changes. If we have your contact details, we may email you about any updates to this policy. Please check this page in future for any updates.
WealthKernel Limited is authorised and regulated by the Financial Conduct Authority, no. 723719, registered in England and Wales, no. 09686970, with a registered office at 41 Luke St, London, UK, EC2A 4DP. All assets held under custody are protected by The Financial Services Compensation Scheme (FSCS) up to a value of £85,000.