Privacy Notice

The Liberate Wealth group of companies operate under the name Liberate Wealth ('we', 'our', 'us', 'LW').
We are registered with the UK data protection authority (the Information Commissioner’s Office or ICO) under the name and number Liberate Wealth Limited (ZB349060) and Liberate Wealth Solutions Limited (ZA213249).

This notice explains how and why we use your personal information when you use our website. A more detailed version of this notice is available upon request that covers use of our services. For information about what cookies are and how we use them, please read our Cookie Policy.

Getting in touch

For any questions, please contact us however you prefer, email: dpo@liberatewealth.co.uk; or write to us at Liberate Wealth, 41 & 43 Maddox Street, Mayfair, London, W1S 2PD. We will respond as soon as soon as possible but no later than within a month of your request, in line with data protection laws.

Where we store or send your data

We may store the data we collect from you outside the UK, or transfer it to organisations outside the UK. When we do this, we make sure that your data is protected and that: the Information Commissioner (ICO) has deemed the country or organisation to provide an adequate level of protection for personal data; or
we have agreed specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If you would like more information on how we transfer your personal data out of the UK, please get in touch by emailing: dpo@liberatewealth.co.uk.

Who we share your data with

We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to a regulator or to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your data’ which explains how we use your data. Your personal data will be used in line with our terms and conditions, these include the potential consequences of third parties using your data.

The types of personal data that we collect

We will collect a range of information about you and your family, including:

• Identity details such as your name, age, date of birth, gender and National Insurance number.
• Contact details such as your email address, telephone and mobile numbers, home address, and social media accounts.
• Financial details such as your salary and other income, savings, investments and other assets, debts and liabilities.
• Family, lifestyle or social circumstances when this is relevant to a specific product or service, such as the number of dependents you have.
• Documents used to verify your identity, to prevent money laundering and fraud.
• Information connected to your product or service with us, such as your bank account details.
• Personal data about family members and/or other named applicants or beneficiaries of products you have with us. In this case you must have the authority to provide their personal data to us.
• Information about your use of our website, including the Internal Protocol (IP) addresses used to access our website, the pages visited and how you interact with the site.
• Information provided by third parties, the scope and extent of which depends on the type of service you are taking from us.
• Sensitive personal data, includes information relating to your health or marital status, and information about children. We only collect and use this information where it is necessary to provide a product or service that you have requested or to comply with our legal obligations.

In the case of children’s personal data, we require consent from a legal guardian to store and process their data.

How we collect your data

We will collect personal information directly from you through a variety of means, including:

• Meetings with one of our financial planners
• Phone conversations with us
• Emails or letters you send to us
• An application form for a product or service
• Registering for one of our seminars or events
• Completing forms on our website
• Through the use of website cookies (some of which are installed via third party providers)

Legal basis for processing your personal information

We process personal information only where at least one of these lawful grounds for processing exists:

• Consent: This means that you have agreed to let us process your personal data.
• Legitimate Interest: This means that we have a legitimate business interest to process your data and that such processing does not override your rights.
• Contract: This means that we are processing your data in relation to a contract between us, such as an employment contract, client or supplier contract, etc.
• Legal Obligation: This means that we are processing your personal data to enable us to comply with the law.

How we will use your data

We only obtain, use and keep personal information where we need it for a specific purpose. The table below sets out the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected.

Most commonly we will use your information in the following ways:

• We have a contract with you. For example, we have agreed to provide financial advice or to manage investments for you and have a contractual agreement to do this.
• We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
• We have asked for, and you have provided, consent to use your information. Please note that you can withdraw your consent at any time – this is part of how the law protects your interests.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to prevent fraud.

The table below explains all the ways we plan to use your personal information and the legal basis we rely on to do so. It also explains what our legitimate interests are where appropriate:

Purpose	Lawful basis for processing including our legitimate interests
To on-board you as a new customer	To fulfil our contract with youTo fulfil our legal obligations to prevent financial crime
To manage your account or investment service	Necessary for our legitimate interests – to recover debts due to us
To monitor your investment on an on-going basis	To fulfil our contract with you
To meet our regulatory obligations to provide you with regular information about your investment	To fulfil our regulatory obligations
To contact you about other products and services we think you may be interested in	Necessary for our legitimate interests – to develop our products and services and grow our business.
To use data to improve our website	Necessary for our legitimate interests – to understand how our customers interact with our website

We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so.

How to make a complaint

If you have a complaint about how we use your personal information, please send an email to dpo@liberatewealth.co.uk and we will do our best to fix the problem. If you are not happy with the way we deal with your complaint, you can refer your complaint to the ICO’s Office, the UK regulator for data protection issues. For more details, visit their website: ico.org.uk or call their helpline number on: 0303 123 1113.

Your rights

You have a right to:

• access the personal data we hold about you, or to request a copy of it;
• ask for a copy of your personal data in a portable (machine-readable) format or request that we send it to someone else;
• ask us to correct inaccurate data;
• ask us to delete your data, though for legal reasons we might not always be able to do it;
• say no to us using your data for direct marketing and in certain circumstances ‘legitimate interests’, research and statistical reasons;
• withdraw any consent you’ve given us; and
• ask a member of staff to review an automated decision.

To do any of these things, please get in touch by emailing: dpo@liberatewealth.co.uk

Changes to this notice

We will post any changes to our privacy notice on this page.