1
Privacy Policy
Netwealth Investments Limited, November 2022
Contents
1.0 Introduction....................................................................................................................................... 1
2.0 Personal Data We May Collect from You .......................................................................................... 2
3.0 Special Category Data........................................................................................................................ 3
4.0 Cookies and Other Technologies....................................................................................................... 3
5.0 How Do We Use Your Personal Data?............................................................................................... 3
6.0 Our Promotional Updates and Communications.............................................................................. 4
7.0 Who Is Your Personal Data Shared With? ......................................................................................... 5
8.0 Automated Decisions ........................................................................................................................ 6
9.0 External Links..................................................................................................................................... 6
10.0 Security and Safeguarding Your Personal Data................................................................................. 6
11.0 Data Retention and Storage of your Personal Data .......................................................................... 7
12.0 Your rights ......................................................................................................................................... 8
13.0 Contacting Us .................................................................................................................................... 8
Appendix 1 ..................................................................................................................................................... 9
Appendix 2 ................................................................................................................................................... 10
1.0 Introduction
This is the Privacy Policy (the “Policy”) for Netwealth Investments Limited covering both
www.netwealth.com (the “Site”) and the mobile app (the “App”). The Site and App are operated by
Netwealth Investments Limited trading as Netwealth (“we”, “us” and “our”). We are a limited company,
registered in England. Our registered company number is 09493628, and our registered office is at
Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ. We are authorised and regulated by the
Financial Conduct Authority (“FCA”), whose address is 12 Endeavour Square, London E20
1JN, www.fca.org.uk. Our FCA firm registration number is 706988. For the purposes of the Data
Protection Act 2018 we are the data controller. You can contact us at: info@netwealth.com.
We are committed to protecting your personal information and privacy on-line. We appreciate that you
do not want your personal information distributed indiscriminately and here we explain how we collect
information, what we do with it and what rights you have.
Information that identifies or can be used to identify a living individual is known as “Personal Data”. All
organisations processing personal data must do so fairly, lawfully and in accordance with applicable data
protection laws, including the Data Protection Law.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
2
This includes the obligation for us to tell you how we will use your personal data. We treat all of our legal
obligations seriously and take all steps necessary to ensure compliance when storing and processing your
personal data.
By using or engaging our Site or App and accepting our services you acknowledge that you have read and
understood this privacy policy. We reserve the right to change this privacy policy from time to time by
changing it on the Site and any substantive changes will be notified to you by e-mail. This privacy policy
was last updated on 15 November 2022.
2.0 Personal Data We May Collect from You
We may collect and process the following personal data about you received directly from you or from your
interactions with us for compliance with a legal obligation:
• Contact details (such as your name, email address, postal address and telephone number) that
you provide by completing forms on the Site, including if you register as a user of the Site,
subscribe to any service, upload or submit any material via the Site, request any information;
• Your date of birth, nationality, country of birth, country of residence, employment status and tax
identification number (e.g. National insurance Number);
• Passport details, driving licence, bank account details and utility bills;
• Your financial circumstances (e.g. assets, liabilities, income and expenditure);
• In connection with an account sign-in facility, your log-in and password details;
• Details of any transactions made by you through the Site;
• Communications you send to us, for example to report a problem or to submit queries, concerns
or comments regarding the Site or its content;
• Information from surveys that we may, from time to time, run on the Site for research purposes,
if you choose to respond to or participate in them;
• Technical information that may include the Internet protocol (IP) address used to connect your
computer to the Internet, your login information, browser type and version, time zone setting,
browser plug-in types and versions, operating system and platform; and/or
• Information about your visit to the Site and App, which may include the full Uniform Resource
Locators (URL), clickstream to, through and from our Site and App (including date and time),
products you viewed or searched for, page response times, download errors, length of visits to
certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods
used to browse away from the page, and any phone number used to call our customer service
number or social media handle used to connect with our customer service team.
A list of the personal data we collect from you when opening an account with us is set out at Appendix 1
to this Privacy Policy.
We collect your personal data from you in a number of different ways, including the following:
• If you provide it when interacting and communicating with us (for example when registering for
our services);
• If you enter into an agreement for the provision of ourservices;
• If you enter a competition or promotion;
• If you make payments or modify your account details; and
• When you visit our Site or App (for example by cookies, your IP address and other browsergenerated information). More information about how we use cookies is provided in our cookies
policy at www.netwealth.com/cookies.
We record all service calls for quality and training purposes, to enable us to deal effectively with queries
and complaints and, in the case of calls where clients place transactions or investment advice is
communicated, in order to comply with our regulatory obligations.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
3
You are under no obligation to provide any such information. However, if you should choose to withhold
requested information, we may not be able to provide you with certain services.
This is because if you have chosen to open an account with us or commissioned investment advice, it is
a statutory requirement for us to obtain, and a contractual requirement for you to provide, certain
information so that we can verify your identity in order to meet our obligations under the Money
Laundering Regulations and other applicable legislation for the purposes of crime prevention. You are
obliged to provide this information in order for us to provide the service and, if you fail to provide it, we
will be unable to provide the service in compliance with our legal obligations.
3.0 Special Category Data
We do not in the normal course of our business aim to collect or process Special Category Data (“SCD”), as
defined by the GDPR and listed below:
• Race;
• Ethnic origin;
• Politics;
• Religion;
• Trade union membership;
• Genetics;
• Biometrics
• Health;
• Sex life; or
• Sexual orientation.
We may, however, record SCD if you disclose it to us, and process this data for specific and limited
purposes, such as your biometric information (relating to physical, physiological or behavioural
characteristics, including for example using voice, fingerprint, or facial recognition or similar technologies)
to help us detect and prevent financial crime, or your health data to ensure that our services are accessible
and appropriately delivered to you, and that you are provided with adequate protection, if you are or
become vulnerable.
We will only process SCD where we have obtained explicit consent or are otherwise lawfully permitted to
do so (and then only for the purposes and activities set out within this Policy).
Where permitted by law, we may also process information about criminal convictions, offences and/or
alleged offences for specific and limited activities and purposes, such as to perform checks to detect and
prevent crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery
and corruption, and international sanctions. This may involve investigating and gathering intelligence on
suspected financial crimes, fraud and threats and sharing data between firms and with law enforcement
and regulatory bodies. Investigating your complaint
4.0 Cookies and Other Technologies
When you interact with the Site and App, we try to make that experience simple and meaningful. Our
cookies distinguish you from other users of our Site and App. This helps us provide you with a good
experience when you browse our Site and use our App and allows us to improve them both. For more
detailed information on the cookies we use and the purpose for which we use them please see our cookies
policy at www.netwealth.com/cookies.
5.0 How Do We Use Your Personal Data?
We use your personal data as is necessary and required to do so by law, or on a contractual basis and in
our legitimate interest (where such interests are not overridden by your interests or fundamental rights
and freedoms) to the extent it is necessary for the proper operation of the Site and App, our services, our
systems, to protect us/our clients, or for the enforcement of our Terms and Conditions.
We may also use your personal data collected from you for the following purposes:
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
4
• Processing applications made by you, managing your accounts, providing our services, contacting
you and servicing our relationship with you;
• Administration and accounting, billing and auditing and other legal purposes;
• to carry out checks on you, such as identification verification checks and anti-money laundering
checks, for the purposes of meeting our obligations under the Money Laundering Regulations
2007 and any other applicable legislation, for the purposes of crime prevention;
• Security and payment verification;
• Dealing with any queries, complaints or problems reported by you;
• Audit the downloading of data from the Site and App;
• Enabling you to participate in our promotions and competitions;
• Enabling you to participate in the interactive features of the Site and App and ensuring content
is presented in the most effective manner for you and your computer or device;
• Notifying you about changes to our service and/or the terms on which the services areprovided;
• Generating statistics on our users, such as the popularity of certain of our services and about the
“traffic” visiting our websites. Before doing this your personal data is anonymised and you are
not personally identifiable; and
Weuse specific functionality provided by Google Analytics, namely Analytics Advertising Reporting, which
is a feature that gathers demographic data via cookies used by advertising providers that you have
interacted with online and third-party tools such as Google DoubleClick. The data we obtain via this feature
is based on assumptions concerning age, gender and interests etc but is aggregated and entirely
anonymous. We use this data to help improve and target our products and services but, importantly, we
do not use this data for any re-marketing activity.
We also use functionality provided by Google to limit the amount of spam traffic acting on our website,
namely Invisible reCAPTCHA. This technology uses cookies and information gathered from your browsing
session to identify bots. Google’s privacy policy can be found here: https://policies.google.com/privacy
and their terms of use can be found here: https://policies.google.com/terms
If you would like to opt-out of the above-mentioned Google products you can do so by turning off tracking
cookies via our Cookie Policy https://www.netwealth.com/cookies
We may also use your personal data to provide you with information about our goods or services we feel
may interest you only if you have given your consent to receiving marketing material from us at the point
where we collected your information. See 'Our Promotional Updates and Communications' for more
information.
In order to monitor and analyse our business we, or a third party acting for us, may use information in
your client and account records to assess client satisfaction and for market research. If you do not wish to
be contacted to participate in client satisfaction or marketing surveys, you can opt out by asking us and
our third parties to stop contacting you by writing to us or by opting out by SMS or email as specified in
the relevant communication. This request will not affect the running of your existing account or the
services you request from us, in respect of which we will still process your personal data.
Unless stated otherwise in this Policy, the legal basis for our use of your personal data will be that this
information is processed for one or more of the legitimate interests described above and/or as is necessary
for compliance with any legal obligation.
6.0 Our Promotional Updates and Communications
Where permitted in our legitimate interest where required by law (as applicable), we will use your
personal information for marketing analysis.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
5
With your prior consent we may also provide you with promotional update communications by email,
secure message, phone or SMS about our products/services.
If you are an existing client, we will only contact you by e-mail, secure message or SMS with information
about goods and services similar to those which were the subject of a previous agreement with you and if
you have not opted out of receiving such communications.
If you are a new client, we will contact you by email, secure message and SMS only if you have consented
to this.
If you do not want us to use your data in this way, you can record your preference when you initially
provide us with your details, contact us in writing at any time to object to marketing or opt out to receiving
marketing by SMS or email at any time. Opting out from such communications will not prevent us from
communicating with you as necessary to manage your account.
7.0 Who Is Your Personal Data Shared With?
You acknowledge that we may disclose your personal data to:
• Entities within our group of companies, which means our subsidiaries, our ultimate holding
company and its subsidiaries, who support our processing of personal data under this policy. If
any of these parties are using your information for direct marketing purposes, we will only
transfer the information to them for that purpose with your prior consent;
• Third parties which we use to carry out the checks that we need to carry out on you, such as
identification verification and anti-money laundering;
• The custodian for the purpose of managing your accounts and providing ourservices;
• A personal pension provider for the purpose of managing your pension accounts and providing
ourservices;
• Other selected third-party service providers that may be located in or outside the European
Economic Area (EEA). These may include:
o Organisations who process your personal data on our behalf and in accordance with our
instructions and the Data Protection Law. This includes in supporting the services we offer
through the site in particular those providing website and data hosting services, providing
fulfilment services, distributing any communications we send, supporting or updating
marketing lists, facilitating feedback on our services and providing IT support services from
time to time. These organisations (which may include third party suppliers, agents, subcontractors and/or other companies in our group) will only use your information to the extent
necessary to perform their support functions.
o We may disclose your personal information to any of our affiliates, or to our agents or
contractors who assist us in providing the services we offer through the Site, processing
transactions, fulfilling requests for information, receiving and sending communications,
updating marketing lists, analysing data, providing IT and other support services or in other
tasks, from time to time. Our agents and contractors will only use your information to the
extent necessary to perform their functions.
o Analytics and search engine providers that assist us in the improvement and optimisation of
our site and subject to the cookie section of this policy (this will not identify you as an
individual).
o Payment processing providers who provide secure payment processing services. Note your
payment card details are not shared with us by the provider.
Third parties to whom your personal data is disclosed to may only use it for the purposes set out in this
privacy policy. A non-exhaustive list of third-party service providers to whom we disclose your personal
data to is included in Appendix 2 to this privacy policy.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
6
If we transfer your data to a service provider outside of the EEA, we ensure that appropriate controls are
in place to protect your data in accordance with applicable data protection laws, such as:
• The European Commission has made an official adequacy decision that the recipient country is a
‘safe’ country for the receipt of personal data; or
• We have entered into a form of contract with the service provider which has been approved by
the European Commission as providing adequate protection for personal data, or if the service
provider is in the US, it has self-certified to the EU/US Privacy Shield Framework.
For a copy of the details of the transfers of, or access to, personal data outside of the EEA and the
safeguards that we have in place when transferring, or allowing access to, your personal data outside of
the European Economic Area, (and for a copy of the safeguards, where applicable) please contact us via
email at info@netwealth.com or using the postal address given at the end of this policy.
We may disclose aggregate statistics about visitors to the Site, the App and clients in order to describe our
services to prospective partners, advertisers, sponsors and other reputable third parties and for other
lawful purposes, but these statistics will include no personally identifiable information.
In the event that we undergo re-organisation or are sold to a third party, you agree that any personal data
we hold about you may be disclosed under appropriate confidentiality terms to our advisers and any
prospective purchasers’ advisers and will be transferred to that re-organised entity or the new owners.
We may disclose your personal information if required to do so by law or if we believe that such action is
necessary to prevent fraud or cybercrime or to protect the Site or the rights, property or personal safety
of any person.
8.0 Automated Decisions
As part of our account-opening process we will carry out automated checks using your personal data, such
as your name, postal address, date of birth, telephone numbers and employment status. These checks
include identification verification checks and financial crime checks and involve our obtaining information
from identity verification agencies and any records held by financial crime prevention agencies, the
Electoral Register and providers of utility services.
We need to carry out these checks in order to meet our legal obligations under the Money Laundering
Regulations 2007 and any other applicable legislation.
We will also carry out suitability checks regarding your choice of investment portfolio. Parameters will
include your financial circumstances, choice of risk level and investment time horizon. These checks may
indicate that a portfolio is unsuitable for you. If our automated processes indicate that a portfolio may be
unsuitable then you will be contacted by a member of the Client Service or Advisory team to discuss your
choices/data and allow you to provide further information which may result in the decision changing.
9.0 External Links
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy
policies or the content of such sites.
10.0 Security and Safeguarding Your Personal Data
We place great importance on the security of all personal information associated with our users and
clients. We have security measures in place to attempt to protect against the loss, misuse and alteration
of personal information under our control. For example, our security and privacy policies are periodically
reviewed and enhanced as necessary and only authorised personnel have access to personal information.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
7
Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we
use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We
cannot guarantee the security of information you submit via the Site or App whilst it is in transit over the
internet and any such submission is at your own risk.
You can also help to protect your personal data, by following the guidelines below:
• If other people have access to your computer, remember to close your browser each time you
log- off and end your session and, if possible, clear any history of the websites you have visited
and that your browser may have saved or “cached”;
• Do not let anyone see your password, PIN or Security Details when viewing on any device;
• Some devices allow you to use your fingerprint or face ID for logging in. If you enable this; feature,
then anyone whose fingerprint or face ID is registered on your device may be able to log in and
view information and/or communicate with Netwealth. Therefore, you must not activate this
feature if you allow other people to access your device using their fingerprint or face ID. You
should delete any other fingerprints or face ID registered on the device first; otherwise,
instructions made by anyone else who has their fingerprint or face ID registered on the device
will be treated as being authorised by you;
• Do not access your account via a jail-broken or rooted device. These devices have had their
security features changed in order to work, which makes them less secure, and means that
fraudsters could access your device;
• Make sure that any device you use complies with the standards and requirements we tell you
about from time to time;
• Always use the latest versions of browser software to access the Site, in order to benefit from
the most up-to-date security features;
• Always use the latest version of the App and install software updates when released, as this will
ensure you have the most up-to-date and robust security features available; and
• Never disclose or otherwise make available your account details to anyone.
11.0 Data Retention and Storage of your Personal Data
We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it
was collected for, as set out above in this policy and for as long as we are required to keep it by law.
We retain copies of our client contracts in order to enable us to deal with any legal issues along with the
information provided to us for identification verification checks and anti-money laundering checks (as
required by law) for 6 years after termination or expiry of our contract with you. Site usage data will be
retained for a period of 3 years in order that we can monitor the performance of the Site.
Details of complaints are retained for 5 years from receipt in accordance with the DISP chapters of the FCA
Handbook and telephone call recordings are retained for 5 years from the date recorded in accordance
with the COBS chapters of the FCA Handbook. If you have a query in relation to how long we retain your
personal data for, please contact us using the contact details provided below.
Your personal information which we collect is sent to and stored on secure servers currently located in the
Republic of Ireland and/or the Netherlands. Such storage is necessary in order to process the information.
8
Personal information submitted may be transferred by us to our other offices and/or to the third parties
mentioned in the circumstances described above (see ‘Who Is Your Personal Data Shared With?’) which
may be situated outside the European Economic Area (EEA) and may be processed by staff operating
outside the EEA.
The countries concerned may not have similar data protection laws to the EEA. Where we transfer your
personal information, we will take all reasonable steps to ensure that your privacy rights continue to be
protected. By using the Site, you agree to this storing, processing and/or transfer.
12.0 Your rights
You have the following rights (unless exemptions apply), which can be exercised by contacting our Data
Protection Officer at info@netwealth.com at any time.
The right:
• To ask us not to process your personal data for marketing purposes;
• To access personal information held about you and to obtain a copy of it (This is known as a Data
Subject Access Request, or DSAR);
• To prevent any processing of a record of personal data that is causing or is likely to cause
unwarranted and substantial damage or distress to you or another individual;
• To obtain the rectification or completion of records of personal data which are inaccurate or
incomplete;
• To restrict or object to the processing of your personal data, including any profiling based upon
it, and to request its erasure. We will not be able to erase personal data where we have a legal
obligation to retain such data for example the results of identity verification checks;
• In certain circumstances, to receive your personal data, which you have provided to us, in a
structured, commonly-used and machine-readable format and the right to transmit that data to
another data controller without hindrance, or to have that personal data transmitted to another
data controller by us, where technically feasible; and
• To lodge a complaint about the way in which your personal data is being shared with a
supervisory authority.
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at
any time by contacting us at info@netwealth.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection
authority (see https://ec.europa.eu/info/law/law-topic/data-protection_en). The Information
Commissioner is the supervisory authority in the UK and can provide further information about your rights
and our obligations in relation to your personal data, as well as deal with any complaints that you have
about our processing of your personal data.
13.0 Contacting Us
Please submit any questions, concerns or comments you have about this privacy policy or any requests
concerning your personal data by email to info@netwealth.com by telephone on 020 3795 4747 between
the hours of 9am to 5pm, Monday to Friday or write to us at:
Netwealth Investments Limited, Two Fitzroy Place, 8 Mortimer Street, London W1T 3JJ.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
9
Appendix 1
The following is a list of personal data which is collected for the purposes of opening an account with
us:
• Name
• Address
• Phone number
• Email address
• Date of birth
• National Insurance number
• Tax identification number
• Nationality
• Country of residence
• Country of Birth
• Second nationality
• Proof of name – passport or driving licence Proof of address – utility bills
• Bank account details
• Employment status
• Employer
• Employment Industry
• Job title
• Income
• Other assets / investments
• Liabilities
• Knowledge, Experience and Understanding of investment
All of the above data is required for compliance with regulatory and/or legal
obligations. This list is correct as of 15 November 2022 and may be subject to change.
Netwealth Investments Limited is authorised and regulated by the Financial Conduct Authority, with firm reference no. 706988. Registered in
England and Wales, with company no. 09493628 and with registered offices at Two Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
10
Appendix 2
The following is a list of processors of personal data that are engaged by Netwealth to provide, or assist
in the provision of services to our clients:
Custodian: SEI International (Europe) Limited
(https://seic.com/privacy-policy)
Personal pension providers: I.P.M. SIPP Administration Limited
Intelligent Money Limited
The James Hay Partnership
Curtis Banks Limited
Suffolk Life Pensions Limited
Identity checks and Anti Money Laundering: SmartSearch
The above list is correct as of 15 November 2022 and may be subject to change.