Privacy Policy
This notice describes how Universum Wealth Ltd uses personal data. It outlines Universum’s data protection obligations and your data protection rights under the General Data Protection Regulation 2018 (“GDPR”).
Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you for you to use our services, how we manage that data and our reasons for holding it. We respect the confidentiality of your information and your right to privacy. We are bound by the General Data Protection Regulation and relevant laws and regulations.
From time to time we may update this Privacy Policy and will notify you of these changes by posting the updated terms on our website www.universumwealth.com
Universum Wealth Ltd is the data controller of your personal information, and this policy applies to the processing of activities by us.
Collection of your data
As part of providing our services, or information about our services, to you, and to ensure we do this in a compliant way, under the authorisation of our regulator and the General Data Protection Regulation, we must collect some personal information from our clients, potential clients, visitors to our website and service providers or suppliers. This may include third parties carrying out credit or identity checks on our behalf. The credit search is required to adhere to money laundering regulations.
We may collect your name and contact details (such as your email address, phone number or address) to send you information about our products and services which you might have expressed interest in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way. If you do not wish to receive this information, please contact us by emailing contact@universumwealth.com or by writing to us at the following address:
Data Protection Officer
Universum Wealth Ltd
13 Austin Friars
London
EC2N 2HE
Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.
Information collected
We may collect the following types of information from actual or potential customers:
- Your full name, address and contact information including but not limited to phone number and email address;
- Your date of birth and gender;
- Your professional and employment details;
- Your identification details such as your passport or driver’s licence;
- Proof of address such as a bank statement or utility bill;
- Your national insurance or tax identification number;
- Criminal convictions data
- Corporate information;
- Information about your income or the source of your funds and wealth including details about your assets and liabilities;
- Your trading experience and transaction history;
- Financial information including investment portfolio details, income levels, taxation details;
- Information regarding relationships you have with banks and/or other financial institutions (including bank details);
We obtain this information through your use of our services or our websites, the onboarding process and from information provided in the course of ongoing customer communication.
We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
We take care to ensure your personal information is safe, secure and is protected from misuse, interference, unauthorised access, loss, modification or disclosure. Your personal information is generally stored in our computer database. Any paper-based information is stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
- passwords are required to access the system and passwords are routinely checked and are not shared;
- data ownership is clearly defined and data is only held where necessary;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- unauthorised employees are barred from updating and editing personal information;
- all computers which contain personal information are secured both physically and electronically;
- data is encrypted during transmission over the network; and
- print reporting of data containing personal information is limited.
We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties where necessary.
When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. We may need to hold some information and maintain certain records for up to 7 years after the end of us providing services to you. This is because we are subject to regulatory requirements and anti-money laundering laws which require us to retain;
- Account opening forms and any documents used to comply for customer due diligence obligations; and
- Supporting evidence and records of trades and transactions with you.
- Details of your communications and relationship with us, for a period of seven years after our business relationship with you has ended.
Data storage
Universum Wealth stores your data on physical and electronic media. Data is safeguarded by Universum Wealth and its Service Providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards. The Data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our Service Providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by Universum Wealth will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data you agree to this transfer, storing or processing. Unfortunately, the transmission of information via the internet is not completely secure. Although Universum Wealth will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.
Collection of personal information
Personal information will generally have been collected directly from you through our onboarding process and other communications with you. We will only use the personal information as set out in this Privacy Policy. We will not retain or have access to any debit/credit card information. We will not collect sensitive information about you without your consent unless an exemption in the regulations applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
We may collect personal information about you from a third party or parties or share information with a third party, such as identity verification services, regulators, an introducing broker, marketing agencies, online vendors and service providers. We may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy and that any such party is subject to the General Data Protection Regulations. Any personal information will only be disclosed to third parties in accordance with this Privacy Policy. We will not sell, lend or rent your personal information.
We may be required to disclose your personal information if requested to do so by law, or if we believe in good faith that such action is necessary;
- to comply with any legal process served on us or in circumstances where we are under a similar legal or regulatory obligation;
- to protect and defend our rights or property; or
- to act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, our Affiliates, or any other user of the Services in any way including, but not limited to, market or price manipulation, payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).
Where required to disclose information we reserve the right to share information, together with your identity with other financial services providers, banks, credit card companies, and appropriate regulatory and legal agencies.
Your personal data rights
- You have the right to be informed,
- You have the right to check what personal information is held by us, at no cost,
- You have the right to have wrongly recorded data amended,
- You have the right to “be forgotten” I.e the removal of your data,
- You have the right to “Opt out”
- You have the right to object to the processing of your personal information,
- You have the right to request the restriction of the processing of your personal information,
- You have the right to request the transfer of your personal information,
You have the right to withdraw your consent.
Concerns or complaints
If you are concerned about us any aspect of our conduct regarding your privacy, you can make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at contact@universumwealth.com We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your response, or you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissioner’s Officer (the ‘ICO’). You can find further details on the ICO website at https://ico.org.uk/
You also have the right, at any time, to complain to the Information Commissioner’s Office. As an independent UK authority, the ICO upholds information rights in the public interest, promotes openness by public bodies and data privacy for individuals.
Universum Wealth Ltd (FRN: 925216) is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859) which is authorised and regulated by the Financial Conduct Authority. Thornbridge Investment Management LLP is registered with the Information Commissioner’s Office, registration number ZA178531. We can be contacted at
Thornbridge Investment Management LLP
13 Austin Friars
London
EC2N 2HE
Cookies Policy
Our website uses cookies. You consent to our use of cookies in accordance with the terms of this policy.
Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies on this website
Universum Wealth does use cookies on its website. Your personal data is not currently collected by Universum Wealth using cookies. Further details are available in our cookie policy.
How to contact Universum Wealth
Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.
If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Universum Wealth has processed your personal data, please contact Universum Wealth by writing to contact@universumwealth.com.
