Privacy Policy

Updated on:

October 30, 2024

About Us

This is the privacy policy for NuWealth Ltd. NuWealth Limited is a wholly owned subsidiary of Quilter plc. Further details about the Quilter Group are available at https://plc.quilter.com/corporate-and-regulatory-information/. NuWealth are authorised and regulated by the Financial Conduct Authority (FCA), whose address is 12 Endeavour Square, London, E20 1JN. Our FCA registration number is 955775. Our registered address is at Senator House, 85 Queen Victoria Street, London, United Kingdom, EC4V 4AB (Companies House company registration no. 10966427). For the purposes of the UK General Data Protection Regulation (UK GDPR), we are the data controller of the personal data you submit to us regardless of the method of submission.

We are committed to protecting your privacy and the security of the personal data we hold and process on your behalf. This Privacy Policy explains how we collect information, what we use the information for, our legal basis for doing so, and what controls you have.

Further details can be found on our website at www.nuwealthapp.com.

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Scope of Laws

We are committed to ensuring your privacy is protected, and we comply with the relevant parts of the following laws:

Data Protection Act 2018
UK General Data Protection Regulation (UK GDPR)

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What information do we collect from you?

Information you give to us

We may collect and process the following personal information about you:

General personal details, which may include:

Your name
Your addresses
Your contact details (email address and/or your telephone number)
Your date of birth
Your national insurance number
Your occupation
Details concerning your financial position

Any communications between us and our clients whether by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding our services, investment or product updates or general comments.
Know Your Customer (KYC) documentation, which may include:
- Copies of identity documents such as passports or driving licences
- Copies of address verification documents, such as utility bills or bank statements
- Any other information needed to comply with our obligations under Anti Money Laundering law, which may include information on your source of funds and financial situation

NuWealth Ltd will abide by the 6 principles proposed by the GDPR, in the table below we suggest how each principle will be dealt with:

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Principle	Actions
Lawfulness, fairness, transparency	NuWealth Ltd will always tell you what data we will process and inform you of the lawful bases we rely upon for that processing.
Purpose Limitation	NuWealth Ltd has communicated clearly on what basis data is processed (performance of a contract and legitimate interests), we will not collect data for unnecessary reasons.
Data Minimisation	The data that NuWealth Ltd collects is necessary for the legitimate interests of the running of the company, data will not be collected for reasons outside of the intended scope.
Accuracy	Data will be required to be accurate, we may ask for customers to update their details on a regular basis.
Storage Limitation	NuWealth Ltd will keep all data collected in a secure database and with a legal timeframe in mind, we aim to securely remove all personal data as soon as it is deemed to be no longer needed unless there is a legal obligation to keep it.
Integrity and Confidentiality	NuWealth Ltd will keep any personal database encrypted to ensure and maintain confidentiality and security. This will prevent the system from any accidental loss, theft, or damage.

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Information we receive from others

We are also working closely with third parties and may receive information about you from them. Like most brokerages, we work with third parties such as Seccl Custody Ltd and Amazon Web Services is our cloud hosting service.

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What do we do with your data?

We use your personal data for the following purposes:

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Providing our services to you

We need to process certain personal information to provide our services to you, which includes verifying and maintaining an accurate record of our prospective and current clients.

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To deliver our services, your personal data may also be transferred to the following third parties:

Compliance consultants, in circumstances where we may need to undertake anti-money laundering checks.

Our technology partners, including our cloud hosting provider Amazon Web Services, to store your personal data securely.
Our custodian partners, to facilitate the NuWealth Ltd accounts.
Our marketing partners, for marketing and regulatory communications to you.

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Contacting you about our services

If you have given us your contact information, we may use these details to contact you about the services we offer such as to email you details of future investments, details of which you may be interested in reviewing.

You may opt out of this at any time by telling us, or if we have contacted you via email, you will be able to respond to the sender.

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Improving our services

We may use your personal data to gain insights into how we can improve our products and services. This will not involve sharing your data with third parties.

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Customer Support and account administration

We may use your personal data to provide you with customer support or to investigate complaints or concerns about our mutual business relationship.

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Our lawful basis for processing your personal data

Under Article 6 of the UK GDPR we are required to tell you about the legal basis under which we collect and process your data.

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We will only collect and process your personal data in accordance with one of the below lawful bases:

Performance of a contract: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering a contract. This lawful basis covers the following purposes:

Providing our services to you

Our legal obligation: This is where the processing is necessary for NuWealth Ltd to comply with the law. This lawful basis covers the following purposes:
- Money laundering regulations
- Terrorist funding regulations
- Anti-corruption regulations
Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
- Improving our service
- Providing you with customer support and administering your account
- Providing you with information offered by NuWealth Ltd.

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Data storage and international transfers

We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the UK GDPR. Your data may be stored securely on servers within the European Economic Area (EEA) which has been determined as having equivalent protections as those provided under the UK GDPR. We will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.

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Your rights

You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice. If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.

You may request a copy of the personal data we hold on you at any time. This information will be provided to you in digital format and free of charge unless we consider your request manifestly unfounded or excessive.

Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by contacting us. ‍

You have the right to request rectification of your personal data if you believe our records are inaccurate or incomplete. In some circumstances, you may request erasure of your personal data. We will comply with such a request if it is no longer necessary to store or process your personal data. You can exercise any of your rights by contacting us via the details at the bottom of this page or through your ordinary means of contacting us.

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How long we will keep your data for

We wish to retain as little personal information as possible, for the shortest time we legitimately can. That generally means that we retain personal information whichever is the longest of the following:

As long as is necessary to fulfil the purpose for which it was collected;
to comply with legal, regulatory, accounting, audit, reporting and internal policy requirements – this will often require us to retain information for a minimum of 5 years;
for the establishment or defence of actual and/or anticipated legal claims; and
as long as any other legitimate reason may require/justify

We will review the above from time to time. If there is no longer a reason for certain information to be retained, such as the end of the business relationship, we will erase it securely.

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What happens if you don’t provide us with the information we need

As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations. Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you.

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Complaints

If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided at the bottom of this page.

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.

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