1. ABOUT US

• 1.1 We are Wealthyhood Ltd, a company incorporated in England and Wales with company number 12190343 and registered address at 9 Kingsland Road, London, E2 8DD, United Kingdom (“we”, “us”, “our” or “Wealthyhood”).
• 1.2 Wealthyhood (FCA Register: 933675) is an appointed representative of RiskSave Technologies Ltd, which is authorised and regulated by the Financial Conduct Authority (FRN 775330).
• 1.3 This Privacy Policy for Wealthyhood describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
  • (a) Visit our website at https://wealthyhood.com or any website of ours that links to this Privacy Policy.
  • (b) Download and use our mobile application (Wealthyhood) or any other application of ours that links to this Privacy Policy.
  • (c) Engage with us in other related ways, including any sales, marketing, or events.
• 1.4 Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@wealthyhood.com.

2. SUMMARY OF KEY POINTS

• 2.1 This summary provides key points from our Privacy Policy. You can find out more details about any of these topics by using the table of contents below to find the section you are looking for.
• 2.2 When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
• 2.3 We may process sensitive personal information, such as your racial or ethnic origins, sexual orientation, and religious beliefs, with your consent or as otherwise permitted by applicable law.
• 2.4 We may collect information from public databases, marketing partners, social media platforms, and other outside sources.
• 2.5 We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law.
• 2.6 We may share information in specific situations and with specific third parties.
• 2.7 We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
• 2.8 Depending on where you are located geographically, the applicable privacy law may provide you with certain rights regarding your personal information.
• 2.9 The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

3. WHAT INFORMATION WE COLLECT

• 3.1 We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services when participating in activities on the Services, or otherwise when you contact us.
• 3.2 The information we collect may include the following:
  • 3.2.1 Personal Information: This includes details such as your full name, a unique identification number (social security numbers or other government identifiers), identification documents (e.g. passport or government-issued ID), date of birth, and age.
  • 3.2.2 Contact Details: This refers to your email address, physical address (and any documents verifying this, such as utility bills), and phone number.
  • 3.2.3 Regulatory Compliance Data: We gather information required to meet our regulatory obligations, such as your bank account details (including any relevant bank statements), IP address, tax residency and identification numbers, citizenship, employment status, source of wealth, and details found in identification documents (including the date of issuance, expiration date, photograph, and the country of issue).
  • 3.2.4 Service Usage Data: We track how you interact with our Services, including statistics such as the frequency of your usage and which features you engage with.
  • 3.2.5 Service Facilitation Data: This includes information necessary for you to access and use the Services, such as your login credentials, payment information (e.g., bank account details for deposits and withdrawals), browser type and version, time zone settings, and the operating system of the device you use to access our Services.
• 3.3 If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:
  • 3.3.1 Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's camera, reminders, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • 3.3.2 Mobile Device Data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
  • 3.3.3 Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
  • This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
• 3.4 All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
• 3.5 We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
• 3.6 Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:
  • 3.6.1 Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
  • 3.6.2 Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • 3.6.3 Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
• 3.7 In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for purposes of targeted advertising and event promotion.

4. HOW WE PROCESS YOUR INFORMATION

• 4.1 We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.
• 4.2 We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • 4.2.1 To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • 4.2.2 To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
  • 4.2.3 To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • 4.2.4 To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • 4.2.5 To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
  • 4.2.6 To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • 4.2.7 To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
  • 4.2.8 To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • 4.2.9 To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • 4.2.10 To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
  • 4.2.11 To carry out our obligations related to your Agreement (Terms of Service):
    We may process your information to fulfill our contractual obligations, including facilitating social features connected to our Services.
  • 4.2.12 To comply with legal and regulatory requirements: We may process your personal information to ensure compliance with applicable laws and regulatory requirements.
  • 4.2.13 To notify you about changes to our Services: We may process your information to inform you about updates, changes, or improvements to our Services.
  • 4.2.14 To administer and improve our Services and internal operations: We may process your information to administer our Services, improve functionality, and ensure smooth internal operations.
  • 4.2.15 To measure or understand the effectiveness of the advertising we serve, We may process your data to analyse the effectiveness of advertisements and to provide ads relevant to your interests.
  • 4.2.16 To analyse, identify, and categorise customers who use or may be interested in the Services: We may process your information to better understand and categorise customers, helping us refine our marketing strategies.
  • 4.2.17 To combine information from various sources: We may combine information received from other sources with the data you provide and the information we collect about you. This combined data is used for the purposes outlined above, depending on the types of data collected.

5. LEGAL BASIS FOR USING YOUR DATA

• 5.1 We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
• 5.2 The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  • 5.2.1 Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • 5.2.2 Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • 5.2.3 Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests. Those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • (a) Send users information about special offers and discounts on our products and services.
    • (b) Analyse how our Services are used so we can improve them to engage and retain users.
    • (c) Diagnose problems and/or prevent fraudulent activities.
    • (d) Understand how our users use our products and services so we can improve the user experience.
  • 5.2.4 Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • 5.2.5 Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

6. DATA SHARING

• 6.1 We may share information in specific situations as described in this section and/or with third parties. Whenever possible, we aim to share as little personal data as possible with our service providers, especially those outside the European Economic Area (EEA) and the UK. When feasible, we anonymise shared data to ensure that your identity cannot be determined based on that data.
• 6.2 We may share your data with third-party vendors, service providers, and contractors (“third parties”) who perform services for us or on our behalf and require access to such information to carry out their work. We have contracts in place with these third parties to help safeguard your personal information. These contracts ensure that:
  • 6.2.1 They cannot use your personal information for any purposes other than those we have instructed.
  • 6.2.2 They are prohibited from sharing your personal information with any organisation apart from us.
  • 6.2.3 They commit to protecting the data they hold on our behalf and retaining it only for the period we instruct.
• 6.3 The categories of third parties we may share personal information with are as follows:
  • 6.3.1 Order Fulfillment Service Providers
  • 6.3.2 Payment Processors
  • 6.3.3 User Account Registration & Authentication Services
• 6.4 We may share your personal data if required by law, such as in response to a valid request from financial supervisory authorities, tax authorities, financial intelligence units, or other relevant public bodies. In such cases, these public authorities will act as independent controllers of the data.
• 6.5 We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• 6.6 We may share your information with our business partners to allow us to offer products and services to you. These partners will also be subject to strict data protection agreements.
• 6.7 We may share your personal data with other Wealthyhood group entities, to provide you with our Services. All Wealthyhood group companies are bound by the same internal data processing principles to ensure robust protection of personal data across the group.
• 6.8 In order to provide you with the best possible service, we cooperate with a range of service providers who help us:
  • 6.8.1 Facilitate participation in financial markets (e.g., trade execution, settlement partners, payment services).
  • 6.8.2 Deliver relevant data (e.g., market data, information concerning financial instruments).
  • 6.8.3 Support and maintain our IT infrastructure (e.g., servers).
  • 6.8.4 Execute marketing and promotional activities.
  • 6.8.5 Analyse and understand customer behaviour to improve our services and marketing efforts.
  • 6.8.6 Fulfil regulatory obligations (e.g., KYC and sanction-related monitoring).
  • In these cases, service providers function as data processors, acting under our instructions and adhering to our data protection standards.
• 6.9 From time to time, we may share aggregated data, such as statistical or demographic information, with service providers to better understand customer behaviour. This allows us to improve our services and more effectively target our marketing efforts. Before sharing this data, we aggregate and anonymise it so that individual customers, including you, cannot be identified.

7. USE OF COOKIES

• 7.1 We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. These tracking technologies help us in several ways, including:
  • 7.1.1 Maintaining the security of our Services and your account.
  • 7.1.2 Preventing crashes and fixing bugs.
  • 7.1.3 Saving your preferences.
  • 7.1.4 Assisting with basic site functions.
• 7.2 We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising. These technologies may be used to:
  • 7.2.1 Manage and display advertisements tailored to your interests.
  • 7.2.2 Send abandoned shopping cart reminders, depending on your communication preferences.
  • 7.2.3 Provide analytics about the usage of our Services.
• 7.3 Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

8. USE OF ARTIFICIAL INTELLIGENCE

• 8.1 As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Policy govern your use of the AI Products within our Services.
• 8.2 Our AI Products may include features such as AI bots, AI insights, AI predictive analytics and AI search.
• 8.3 All personal information processed using our AI Products is handled in line with our Privacy Policy and our agreements with third parties. This ensures the high security of your personal information.

9. HOW LONG WE KEEP YOUR DATA

• 9.1 We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
• 9.2 As a regulated financial institution, we are legally obligated to retain certain personal and financial data even after your account has been closed. Once the data is no longer required under applicable laws or the jurisdictions we operate in, we will securely delete it. Typically, our data retention period is 5 years following the conclusion of our business relationship with you. This period is mandated by law to ensure compliance with our legal obligations.
• 9.3 In some cases, we may need to retain your personal data for a longer duration to meet additional legal requirements or if we have a legitimate interest, such as a requirement from our partners, that necessitates extended data retention.

10. KEEPING YOUR DATA SAFE

• 10.1 We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
• 10.2 Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. INFORMATION FROM MINORS

• 11.1 We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
• 11.2 If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.
• 11.3 If you become aware of any data we may have collected from children under 18, please contact us at hello@wealthyhood.com.

12. YOUR PRIVACY RIGHTS

• 12.1 In some regions (like the EEA and the UK), you have certain rights under applicable data protection laws. These may include the right to:
  • 12.1.1 Right to Access: You have the right to request access to the personal information we hold about you. However, please note that this right may be restricted by our regulatory obligations, and we may not be able to provide access to data if doing so would violate legal requirements.
  • 12.1.2 Right to Rectification: You have the right to ask us to correct or update any inaccurate or incorrect information we hold about you.
  • 12.1.3 Right to Erasure and Restriction of Processing: You can request that we delete, stop processing, or limit the use of your personal data. However, if we are legally required to retain the information for a certain period, we may not be able to fulfil your request until that retention period has passed.
  • 12.1.4 Right to Data Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format. You may also request that we transfer this data to another data controller, provided the data was collected with your consent, under our Agreement, or through automated means.
  • 12.1.5 Right to Withdraw Consent: Your consent is given voluntarily, and you may withdraw it at any time. However, withdrawing consent may mean that we are no longer able to provide certain Services to you. You also have the right to withdraw consent from receiving marketing communications. We offer an option to unsubscribe from such communications in each email via an unsubscribe link, though you will continue to receive important information related to the Services and our Agreement.
• 12.2 Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
• 12.3 Account Information: If you would like to review or change the information in your account or terminate your account, you can:
  • 12.3.1 Log in to your account and update your user account.
  • 12.3.2 Contact us using the contact information provided.
• 12.4 Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

13. CONTROLS FOR DNT FEATURES

• 13.1 Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised.
• 13.2 As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

14. UPDATES TO THIS POLICY

• 14.1 We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

15. CONTACT US ABOUT THIS POLICY

• 15.1 If you have questions or comments about this policy, or if you have any concerns about our use of your personal data, you can make a query or a complaint to us by email at hello@wealthyhood.com and we will do our best to address the issue.