1. Who we are
Investwizz Trading Limited (Company No. 16956240 | FRN: 1050679) ("Investwizz", "we", "us", "our") is a company registered in England and Wales and is an appointed representative of WealthKernel Limited, which is authorised and regulated by the Financial Conduct Authority (FRN: 723719). Registered office: C/O Investwizz Ltd, Room 347, The Engine Room, 18 The Power Station, London, England, SW11 8BZ.
This Privacy Policy explains how we collect, use, store, and share personal data when you use our application, website, or services. This Privacy Policy reflects current UK data protection requirements and will be updated where required to reflect future legal or regulatory changes.
Investwizz and WealthKernel are joint data controllers for the personal data described in this policy.
2. Data we collect
- Waitlist data: If you join the Investwizz waitlist, we collect your email address, your communication preferences, and basic attribution data such as the page you joined from. This is collected directly from you and, where applicable, indirectly through website attribution data.
- Account data: Your name, email address, and any profile information you provide during registration. This is collected directly from you.
- Financial data: Account balances, transaction data, and portfolio information accessed through Open Banking connections with your explicit consent. We access this data in read-only mode and do not store your banking credentials. This is collected indirectly from your connected account provider or financial institution, with your consent.
- Usage data: How you interact with the app, pages visited, features used, session duration, and limited attribution data relating to how users find Investwizz. This data is used to improve the product, understand app performance, and measure the effectiveness of our marketing activities. It is not sold to third parties. This is collected indirectly through your use of our website, app, and services.
- Device data: Device type, operating system, app version, and anonymised identifiers for crash reporting and diagnostic purposes. This is collected indirectly from the device you use to access our website, app, or services.
Investwizz does not track users across third-party apps or websites for advertising purposes, as defined by Apple's App Tracking Transparency framework.
- Identity Verification (KYC) and Compliance Data: Where you apply for regulated investment services through Investwizz, identity verification, anti-money laundering (AML), sanctions screening, and other regulatory compliance checks may be carried out by WealthKernel Limited and its appointed service providers. As part of this process, personal information required to satisfy regulatory obligations may be collected and processed by those providers in accordance with their respective privacy notices. Investwizz may receive confirmation of the outcome of such checks where necessary to provide our services and comply with applicable legal and regulatory requirements. This may be collected directly from you and indirectly from WealthKernel Limited, identity verification providers, screening providers, or other regulated service providers.
3. How we use your data
We use your personal data to: provide and improve the Investwizz service; verify your identity in accordance with Financial Conduct Authority requirements; send service notifications (not marketing, unless you opt in); comply with legal and regulatory obligations; and investigate and prevent fraud or misuse of the platform.
If you join the waitlist before we launch, we will use your email address to send updates about the launch, provide early-access communications, and share operational messages regarding the waitlist itself.
We do not sell your personal data. We do not use your financial data to generate advertising profiles or share it with marketing partners. Your financial data is used solely to provide the service, support investment functionality, and comply with regulatory requirements.
4. Our legal basis
We process your personal data under the following lawful bases as defined in UK GDPR:
- Waitlist data: consent where you opt in to receive marketing communications, and legitimate interests where we use limited attribution data to manage and assess the waitlist.
- Account data: contract performance, where processing is necessary to create and manage your account and provide the Investwizz service.
- Financial data: contract performance, where processing is necessary to provide the Investwizz service. Where financial data is accessed through Open Banking, this is done with your explicit consent through the relevant Open Banking consent process.
- Usage data: legitimate interests, where we use this data to improve the product, understand app performance, prevent misuse, and assess the effectiveness of our services.
- Device data: legitimate interests, where we use this data for security, diagnostics, crash reporting, and service improvement.
- Identity Verification (KYC) and Compliance Data: legal obligation, where processing is necessary to comply with Financial Conduct Authority regulatory requirements, anti-money laundering legislation, sanctions screening requirements, and other applicable legal and regulatory obligations.
- Marketing communications: consent, where we send marketing communications. We will ask for explicit consent first.
4a. Marketing communications
Where you have opted in, we may send you marketing communications about Investwizz, including launch updates, product updates, offers, promotions, waitlist updates, and early-access communications. Consent may be obtained when you join the waitlist, create an account, use our website or app, or select a marketing preference.
Marketing may be sent by email and, where available and selected by you, by SMS, push notification or in-app message. You can opt out at any time by updating your communication preferences where available or contacting us at help@investwizz.co.uk, and you can opt out of marketing emails through the unsubscribe link in marketing emails.
Opting out of marketing will not stop us from sending service, transactional, regulatory, security, or other non-marketing messages relating to your account or use of Investwizz.
5. Data sharing
We may share your data with: regulated financial infrastructure providers, including WealthKernel Limited, who act as our Principal and provide regulated investment and custody services; identity verification partners; HMRC or other regulatory bodies where legally required; and our cloud infrastructure providers.
Where data is transferred outside the UK or EEA, appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses.
6. Data retention
We retain your account data for the duration of your active relationship with Investwizz and for up to 6 years following closure, in accordance with Financial Conduct Authority record-keeping requirements.
7. Your rights
Under UK data protection law, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Request deletion of your personal data in certain circumstances
- Restrict how we use your data in certain circumstances
- Object to processing based on our legitimate interests
- Data portability, allowing you to receive your data in a structured format
- Withdraw consent at any time where processing is based on consent
- The right to object to certain types of profiling or automated processing where applicable
- The right to make a data protection complaint
To exercise any of these rights, contact us at help@investwizz.co.uk.
We aim to respond within one month. In some cases, we may extend this timeframe where permitted by law, for example, if your request is complex. We will keep you informed if this applies.
8. Cookies
Our website uses strictly necessary cookies to function. We do not deploy advertising or tracking cookies without your explicit consent. Where analytics technologies are used to improve our services and understand usage patterns, they will be deployed in accordance with applicable data protection laws and, where required, only with your consent.
9. Data security
We implement appropriate technical and organisational measures to protect personal data, including encryption, access controls, and secure infrastructure. We also maintain safeguards designed to prevent unauthorised access, disclosure, alteration, or loss of personal information.
9a. Children's privacy
Investwizz is intended for individuals aged 18 years and over. The Investwizz app may be accessed by individuals aged 16 years and over.
We do not knowingly collect personal data from anyone below the applicable age requirement for the relevant product or service. Where we become aware that such data has been collected without an appropriate legal basis or authorisation, we will take reasonable steps to delete it promptly.
Parents, guardians, or individuals who believe that an underage person has provided us with personal information should contact us so that we can investigate and take appropriate action.
10. Contact
For privacy-related queries and data rights requests: help@investwizz.co.uk. For general enquiries: help@investwizz.co.uk
Investwizz is registered with the Information Commissioner's Office (ICO) as a data controller. Registration reference: ZC078598
Complaints: You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your personal data has been processed unlawfully or if you are dissatisfied with how we have handled your data protection complaint. You can contact the ICO at ico.org.uk/make-a-complaint, by telephone on 0303 123 1113, or by post at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.